Hello Summer Clerk! I hear from Bill Waters that you are our resident expert on the issue of adverse possession and satisfying its various elements, and I am hoping that you can put that knowledge to use on a potential client matter. The client is Frank Adler, a citizen of Franklin, who lives about 40 miles outside of town. He was referred to us by one of our most important clients, the Franklin Cattle Grazing Association and drove all the way in to Franklin City this morning to talk with me. I met with him this morning. The important facts and quick background on the case: Mr. Adler, who owns the old 800-acre Rambling Ranch property about 40 miles outside of town within the state boundaries of Franklin is involved in a dispute over a piece of land he says he bought back in September 1999, at the same time he purchased the Rambling Ranch property. The seller of the old Rambling Ranch property at the time was a Mr. Rob Pryor, now deceased. According to Mr. Adler, when Pryor sold him the Rambling Ranch property, it was all properly fenced and bounded, but Pryor also told him the sale included the large unfenced 40-acre tract of scrub land adjacent and immediately to the east of the Rambling Ranch. It wasn't much good for growing anything, Pryor told Mr. Adler, but was suitable for grazing a small herd of cattle nine months out of the year, excepting the winter months when it got really cold. In fact, Pryor described this tract to Mr. Adler as the "Scrub 40 Lot." Mr. Adler told me he had the documents to prove that the Scrub 40 Lot was included in the sale when he purchased the Rambling Ranch in 1999. He showed me his deed, but unfortunately, Pryor's writing on the deed simply gives a metes and bounds description of the Rambling Ranch property. It says nothing about "Scrub Lot 40" nor does it refer to the adjacent land to the east of Rambling Ranch being included in the sale. When I asked Mr. Adler if he had ever read the deed from Mr. Pryor to see what it actually contained, he replied that he tried to read it at the time Pryor gave it to him "for a look," but it was full of what he called "legal mumbo jumbo" that he didn't understand. He remembers saying it all looked "good and fine," and that he had always assumed the deed included the adjacent land, and that's why he's always grazed his milk cows on "Scrub Lot 40" since 1999. After further questioning, Mr. Adler admitted he only grazed his cows on Scrub Lot 40 about nine moths out of the year. He says that because of the harsh Franklin winters, he always moves his small herd of cows into the Rambling Ranch's large heated livestock shed for the winter months. Mr. Adler told me that last week, while he was out with his cows on Scrub Lot 40, a lady by the name of Audrey Auslander stopped her car, got out, and asked Mr. Adler what he wasdoing with those cows on her land, which she referred to as "Scrub Lot 40." When Mr. Adler tried to assure her that he owned Scrub Lot 40, she pulled out a xerox copy of a deed, signed by Rob Pryor, granting her the land described as "Scrub Lot 40" in September 1998 before she returned to her home in Australia. As she explained to Mr. Adler, Ms. Auslander loved ostriches, and she he intended to one day use the 40 acre tract of scrub land she had purchased from Mr. Pryor as a rescue ranch for abandoned pet ostriches in the United States. However, when she returned to Australia, she learned there were no abandoned pet ostriches in the United States, and so abandoned her plans for using the tract of land. Now, however, as she explained to Mr. Adler, she had returned to Franklin after these many years of long absence, to begin a new project, aimed at breeding pet ostriches in the United States. She demanded that Mr. Adler stop grazing his cows on her land henceforth. She also gave him the copy of her deed from Mr. Pryor, telling Mr. Adler to "go show that to your lawyer, Mr. Trespasser!" Mr. Adler does not care for ostriches, and I've looked at the Pryor to Auslander deed and made a quick check of the country land records on the registrar's website. It looks like Ms. Auslander recorded her deed in 1998 and seems to have acquired a valid title to the 40 acre tract of land from Mr. Pryor. Assuming that Ms. Auslander did validly acquire title to Scrub Lot 40 from Pryor, and that she was the true owner of the land at the time that Mr. Adler, one year later, believed he had validly purchased the tract from Pryor, can Mr. Adler assert a claim to title to the tract acquired by adverse possession? We want to argue that Mr. Adler can satisfy all the elements of an adverse possession claim under Franklin law. Using the same cases and outline you used in the assignment for Bill Waters (no need to reinvent the wheel here), Do a short analysis, addressing whether Mr. Adler can assert an adverse possession claim to Scrub Lot 40. Please do the memo using the IRAC (Issue/Rule-Reason for the Rule/Analysis/Conclusion) mnemonic, (or whatever organizational scheme you learned in law school). Although I expect you can draw heavily from the work you did for Bill Waters, please tailor your rule explanation to the issues implicated by the facts in the Adler v. Owen case. This should be a "client-ready" draft; I am on a tight deadline, and I would like to be able to just drop your work product into my memo.