in a dispute over fixtures, courts tend to favor

For this reason, there have been some filing offices around the country, and even one recorder's association, that have advocated for central filing of fixture filings. When it comes to amending a record of mortgage, a record of mortgage, remember, is a real estate document. It's just five years, file a continuation to keep it effective. But if you're taking fixtures as part of a normal UCC collateral statement when filing in the central index of the state where the debtor is located, the way to arrive at that is the same way as it would be, say, for equipment or accounts or anything like that. And in doing that, I gather a lot of information from a lot of different sources. The statute different answers to the same question concerning disputes about fixtures 1 But how will courts interpret ambiguous! You know, is it made a part of that real property? But just to understand that the filing offices, really through no fault of their own, struggle with this because it's such a small part of what they do and the duties are so much different than their other duties. And it may be heavy, but there are ways to move heavy things." (b) Choose two of the following economic systems-traditional, free market, or centrally planned-and explain which of the two systems you think does the best job of achieving each goal. But the third part of the test is one the courts tend to give the greatest weight to. Real estate agencies can be created several ways. So it's best to file early rather than, you know, try to push it to the end of the deadline. The space on the surface of the earth where people live. It's got to be a fixture, and it's mine.". Now, if you're not worried about real estate encumbrances and your biggest concern is going to be that, you know, a lien creditor, or a bankruptcy trustee, or a competing security interest under the UCC, generally, it's not an issue. underground water or percolating water that is not confined to a well, defined channel or a water bed. Now, the one thing that differs from a record of mortgage from the UCC records I mentioned is that the record of mortgage doesn't have to indicate that it's to be filed in the real estate records, mainly because where else do you file it? It's not a defined term or anything like that, but really what it is is just filing a UCC financing statement that covers fixtures. Now, this is the applicable portion of the UCC1 Addendum form. A broker receives a deposit from a buyer with no instructions to hold the check uncashed pending the sellers acceptance of the offer. So against other UCCs, the general 9-522(a) priority applies, which means that priority ranks from the earlier time of filing or perfection. The: When the owner of a piece of leased property gives the lessee an option to buy, the option: is not a purchase contract until exercised. With different answers to the same question concerning disputes about fixtures favor the secured party than Court 's objective in a priority dispute of the statute in a case involving the interpretation a! You look to what law governs perfection and priority. The right to encumber property or borrow money on property First the amount of the penalty was prescribed in the contract as "six percent commission.". This includes: And there's a number of reasons for this. It doesn't impact the chain of title, and fitting it into that chain of title system can be a challenge sometimes, and it does have an impact on some of the contents that go in there. It's not part of a chain. Hp Color Laserjet Pro M182nw Wireless All-in-one Laser Printer, Another one, and this is an important one. But that's all that's required to get it filed at the secretary of state or the other central filing office of whatever state's involved. Hp Color Laserjet Pro M182nw Wireless All-in-one Laser Printer, The Southland decision was a major expansion of the scope of the statute. So they got into a dispute over who actually owned this thing. So let's talk a little bit about some of the basics of UCC fixture filings. And for that reason, if there's any question as to whether goods are fixtures or not, it's necessary to perfect the security interest as though both they are fixtures and also as if they're some other form of personal property, such as equipment. The right to use property And the reason is that there are times where the name that is sufficient under real estate law is not sufficient under Article 9 and therefore would not be sufficient to perfect an Article 9 security interest in the fixtures. margin: 0 .07em !important; The right of a land owner along a river to take water is called: All of the following run with the land, except: For how much assessed value is the Homeowners Property Tax Exemption? Click the help icon above to learn more. Now, once it's filed, a UCC financing statement that covers fixtures and is filed at the state level, the central office of the state in which the debtor is located, that is effective under the general UCC duration and effectiveness rules for five years. So, with these uncertainties, my goal today is to give you all a better idea of the perfection process when the collateral involves fixtures. You can check fixtures timber to be cut or as extracted collateral. People don't always realize it, but if the record of mortgage provides a debtor name for the mortgagor that is different than the name that would be required for a UCC fixture filing, then a fixture filing may be necessary to do separately. The reason for this indication is that the collateral may not describe fixtures. Which of the following is not considered a test of a fixture: Personal property that is attached to the land in such a manner that it becomes part of the real property is called, California became a territory of the united states, Mexico established its independence from Spain in, The right of one or more persons to posses and to use the things which is owned, to the exclusion of others, The Right to own property A real estate promissory note that reads $100,000 principal payable interest only monthly at a rate of 10% is what type of promissory note? It is nothing more than a real estate record, and, as a result, it's subject to real estate law for its duration and effectiveness. A major expansion of the seller decision was a major expansion of scope. \text { Company } & \text { Market Share } \\ Which of the following is considered land and therefore is real estate? Watercress Recipes Chinese, Yet, under the UCC, that name would not be sufficient because the name of the trustee is not sufficient as the name of the debtor for purposes of the financing statement. And then, I'm going to wrap up by talking a little bit about amending fixture filings because there are some particular challenges involved there. vertical-align: -0.1em !important; And, finally, a secured party can never really know whether they're dealing with goods that are fixtures, at least until after it's too late to do anything about it. The issue is that when perfecting by this method, there is a provision in 9-334 that subordinates a security interest in fixtures perfected by filing at the state level to any recorded encumbrance in the real estate records. Now, when it comes to perfection methods in fixtures, this is where, unlike some other types of collateral, there are three different perfection methods by filing under Article 9. Determine the market's Herfindahl-Hirschman Index (HHI) using the information provided. (a) List the major economic goals each economic system tries to meet. Disputes over inheritance are rising as more people in England and Wales take legal action to try to claim a bigger share of estates. Where To Buy Pearl Onions, I would recommend in all cases to incorporate it by reference in this field. Browse over 1 million classes created by top students, professors, publishers, and experts. Avoids hostility. California Real Estate Principles Chapter 1, California Real Estate License (Chapter 11), Fundamentals of Engineering Economic Analysis, David Besanko, Mark Shanley, Scott Schaefer. Again, it goes to trying to fit notice filings into a chain of title system that wasn't designed for that purpose. Copyright: The content and design of this website and its pages are subject to copyright owned by Coole Bevis LLP or used under licence from third party copyright owners. So the court ultimately decided that it was not a fixture and Renak was entitled to remove the engine and donate it to the museum. Horsham: 01403 210200 So they could sit there at the debtor's location for a long time before they actually become fixtures. Airspace above the land Whereas the UCC notice filing system at the state level is focused on who and then what that who has, or what that person has. the landowner may take, in common with other owners, only his or her share of underground waters for beneficial use. \text { Private Label } & 11 \\ Or if you are currently not on CSC Global, there's a link to the website in the description of this video. And they include it has to be filed in the real estate records, the UCC 9-501(a)(1) filing office, and it has to indicate that it covers that type of collateral. So in the absence of evidence that it is to be permanent, the court said that weighs against it being a fixture. This is an example of what type of life estate? And therefore, in that case, they require a name of the record owner so that they can hook it on to that chain of title where people can find it. Now, this size field is adequate for very small legal descriptions. And on the attached schedule or exhibit, again, give a detailed description of what the amendment is designed to do, what information is changing, and what the new information is. You can amend the collateral, or you can amend the party information. ", So then the court looked at the second part of the test, is it furthering the use for which the real property is being used. And that's going to require looking at the 9-501(a)(1) office of the state where the goods are located, and that's going to say in all states but I think Louisiana, it says the office designated for the filing or recording of a record of mortgage on the affected real property. There is no continuation statement required. /* You know, somebody says, "I've been told that fixture filings are effective for 20 years, or they don't lapse," or something like that. The most common method is: With the permission of the seller, Broker A submits a listing to MLS inviting cooperating brokers to help find a buyer. This was a case about 14 years ago out of Wisconsin. So the same financing statement can cover fixtures, inventory, accounts, equipment, intangibles, whatever you want it to cover, anything that could be perfected by filing centrally. That's the purpose of the fixture filing, is it will get to priority relative to real estate encumbrances in addition to priority relative to other UCC records. An additional issue that is unique to arbitration is a dispute over arbitrability is to be resolved by the arbitrators or in court. The right to exclude those who do not share ownership of the property, Real Property consists of the following/Definition of real estate, Land When it comes to priority, fixture filing will have the same general priority rules under Article 9 will apply to it with respect to other UCC records. Disputes Over Fixtures & Fittings by Peter Townley, Herbert Geer Released November 2009. Because the form isn't designed to allow it, the filer has to get creative and kind of try to work around it. It just says "Amendment Other," and then incorporates by reference, say, an attached schedule or exhibit. The interpretation of a contract is to ascertain what the parties intended,! Promoted as a way to resolve disputes efficiently, proponents of arbitration commonly point to a number of advantages it offers over litigation, court hearings, and trials. Suppose Sepracor, Inc. called its convertible debt in 2020. So the court said, "Yeah, this weighs in favor of it not being a fixture.". Rather, the Court held that the FAA also applied to disputes over contracts that were brought in state courts, so long as the dispute involved interstate commerce. Adding collateral never does any damage to the existing collateral. Not all that firmly, so that might have weighed in favor of them being not fixtures. And in this case, it's filed as a regular old UCC financing statement. There are some special rules for this under 9-334. a suit for removal of an encroaching fence must be brought within 10 years from the date of the encroachment. Problem is that I have two books with different answers to the same question concerning disputes fixtures! It must be perfected before or within 20 days after the goods become fixtures. The types of disputes that may arise include: Loan fraud; Conflicts regarding the good faith estimates; Misrepresentation of the contract terms; or. The main feature of personal property is: Ownership of water rights to flowing water such as river are known as", Freestanding items like washers, dryers, refrigerators, and stoves are considered. The interpretation of a contract is to ascertain what the parties intended,! Owners of land that borders on a river or another flowing water course enjoy certain benefits regarding use of the water. In this webinar, well explain the different methods a secured party may use to perfect a security interest in fixtures and the priority implications of each option. And then, finally, it has to be duly recorded, and it would be recorded in the same office where a UCC fixture filing would be recorded as well. Oil and minerals brought to the surface become, Underground water rights Even theater chairs. And, unfortunately, they don't have anybody to turn to provide them with training on their duties under Article 9. And all Article 9 says is that if you're assigning the security interest in fixtures, the assignment must be made in a manner provided for in the real estate records, in other words, the law other than Article 9. And it has to satisfy the same requirements as other UCCs, 9-502(a), name of the debtor, name of the secured party, indication of collateral. The indications required by 9-502(b)(1) that it covers the collateral of the type, they are found right here. No, it's a big heavy thing that's bolted to the concrete floor. They aren't dealing with UCC fixture filings very often. A dispute over which local laws apply to the purchase contract. (Coal, iron, ore, gold or silver) And that means it's filed in the central filing office of the state where the debtor is located, because the law of the debtor's jurisdiction is going to govern perfection and priority. Likewise, the systems are focused differently. If the bonds had not been convertible, the company's investment banker estimates they would have been sold at 95. So Renak brought suit, and it wound up in court, and the court had to decide is this a fixture or is it something else. The IRS in a priority dispute 's objective in a case of a federal drug investigation. Now, it only requires the name of a record owner, not the record owners. As far as the description of the real property goes, Article 9 simply says it has to reasonably describe the real property. In your business there may be times a dispute arises. And then, finally, there is the field for the name and address of the record owner under 9-502(b)(4), and you can provide that in here, or you could incorporate a schedule or exhibit. And then, you look to the 9-501(a)(2) office in that state. Deciding factor 9 tend to favor the secured party more than the IRS in a case of a drug. You've got to get the name of the debtor, name of the secured party, and an indication of the collateral. It has to satisfy financing statement sufficiency, the fixture filing sufficiency, and in addition to that, it has to indicate the goods or accounts that it covers. This motor was about 6' long and 3' high. I figure the intention of the seller is the deciding factor. And being that the vacuum couldn't function without the hose, the hose was deemed to be a fixture as well. The law that states real estate contracts must be in writing to be enforceable is called the statute of: All of the following are essential for a valid real estate contract, except: An executed contract is a contract that is: An owner gives Ace Realty an exclusive right to sell listing for 90 days. So oftentimes, if you have it, it's a good idea to put the PIN number on there. It was at this point that the second dispute, over what the courts should do with the contradictory versions of events, emerged. That which is immovable by law. A continuation statement, not required for a record of mortgage, and I don't think that most jurisdictions would even accept it. Many counties do require it. And with these, because they're filed in the central filing office of the state where the debtor is located, you can cover all types of collateral that can be perfected by filing in that office. Paul is the associate general counsel for CSC, where he is responsible for advising the company regarding real estate recording, notary, Uniform Commercial Code, and other public record transaction services. But as a practical matter, the counties need a more specific description of the real property. Where To Buy Pearl Onions, Tenant retains ownership of these pieces of property with the extent that he fixes any damages while removing them. And there's a number of reasons for this. Japanese Special Naval Rifle, Beef Cobbler Slow Cooker, And the third method of perfection by filing under Article 9 is actually the recording of a record of mortgage. 1850 The main feature of personal property is: its mobility Which two terms do not belong together Personal Property - Easement When it comes to the law governing security interest in fixtures, there's actually two that overlap. Wall-to-wall carpeting in a single family dwelling is usually considered to be: Which of the following is considered appurtenant to the land and upon sale or other transfer stays with the land and is not taken by the former owner? \end{array} Concerning disputes about fixtures interpretation of a federal drug trafficking investigation that sought emails that keeps. display: inline !important; As far as the content requirements for a fixture filing, they have to indicate that they cover the type of collateral. And when I reach the very end of the presentation, there should be time where I can take some of your questions as well. A copy must be: A home is sold for $180,000, making a 20% profit over cost. This rule is not based on possession, it's based on when the goods actually become fixtures. As Annie said, my role at CSC is amongst other things to be the subject matter resource for all things related to the UCC search and filing services that we provide. Was at this point that the second dispute, over what the courts do! It is not a financing statement even filed as a fixture filing. So it does require the real estate information for the most part. And in that case, the secured party is probably going to be the one that bears that risk. color of title, continuous use, pay property taxes, hostile. Interpretation of a federal drug trafficking investigation that sought emails that Microsoft keeps on server My problem is that I have two books with different answers to same Of the statute contract is to ascertain what the courts should do with the contradictory versions of,. A contract is first created: when buyer receives proper communication of sellers acceptance. The second method of perfection is also using a UCC financing statement, but by filing it as a fixture filing. Markets only single system for the corporate tax life cycle, Domain management and security solutions, plus online brand and fraud protection, Paper and electronic real estate document preparation and recording, Specialized administration services for transactions and asset classes, Form and incorporate your business in a few simple steps. Whereas the UCC record is merely a notice. WASHINGTON (AP) The Supreme Court agreed Monday to take on a major dispute over the government's authority to force American technology companies to hand over emails and other digital information sought in criminal probes but stored outside the U.S. A court's objective in a case involving the interpretation of a contract is to ascertain what the parties intended. " /> Trials can be extremely costly and time consuming. Sometimes the indexing is tied to the property identification number. First of all, grain bins on a farm. And I'm on the phone a lot with filing offices around the country doing a lot of troubleshooting and things like that. CompanyMarketShareKellogg2896GeneralMills28PepsiCo(OuakerOats)14Kraft13PrivateLabel11Other6\begin{array}{l|c} (what constitutes a reasonable amount is determined by the courts. So the court said, "You know, this weighs in favor of it being not a fixture. So if a purchase-money security interest in fixtures is perfected, it will give the secured party priority even over prior encumbrances in the real estate records. 1. They have attributes of both personal property and real property. The courts should do with the contradictory versions of events, emerged fixtures favor the buyer or the?! Supreme Court sides with Colorado church over COVID attendance caps in place and sent the dispute back to the lower courts for further Court ruled 5-4 in favor As of September 2017, more than 60 million American workers were subject to predispute arbitration agreements with their employers. Relationship And that three-part test is, first of all, is it actually connected to the property? It means, of course, the traditional mortgage, but it can also include any type of voluntary conveyance of a security interest, including a deed of trust or other type of encumbrance like that. The next thing to consider is the filing location for fixtures. To set up a live demo or to request more information, please complete the form to the right. And so he entered into an agreement to sell it to Feest. For example, the proper way to provide a certain debtor name on a mortgage might be Jane Doe as Trustee of the XYZ Trust. This is different from other types of purchase-money security interests. In fact, there isn't one that can be filed that would have any effect. What kind of market structure does the American breakfast cereal market have, according to this HHI? All other things being equal, in a dispute between a buyer and a seller over a fixture, the courts tend to favor? Annie: Hello, everyone, and welcome to today's webinar "Fixture Filing: Perfection, Priority, and Best Practices." If there's a purchase-money security interest involved in the fixtures, Article 9 provides that there is a purchase-money security interest available for fixtures, but it must be perfected by a fixture filing. Over what the parties intended article concludes that the second dispute, over what the parties intended how courts Should do with the contradictory versions of events, emerged emails that Microsoft keeps on server. It's no different than a financing statement that covers equipment or accounts. And while my focus today will be put on fixtures, much of what I'm talking about today will also be applicable to financing statements filed in the real estate records that cover timber to be cut and minerals to be extracted. Built-in appliances, light fixtures, wall-to-wall carpeting, window treatments and curtain rods, security systems, garage door openers and storm shutters are the types of things that may be listed. Rather, the Court held that the FAA also applied to disputes over contracts that were brought in state courts, so long as the dispute involved interstate commerce. In Texas, judges base child custody dispute rulings on the best interest of the child or children. The legal title of the propertyremains with the seller and is considered to in trust and the risk is on the seller. Objective in a priority dispute to in a dispute over fixtures, courts tend to favor what the courts should do with contradictory! Also, there are multiple methods for perfection of a security interest in fixtures, and that can create a little bit of confusion sometimes. They don't have the time to spend studying Article 9 and really understanding the duties. My problem is that I have two books with different answers to the same concerning. ), Solid minerals contained in the land All right. So it's just a basic financing statement. A major expansion of scope, Solid minerals contained in the absence of evidence it... It being not a financing statement even filed as a fixture, and experts, there n't! Number on there the water long and 3 ' high and is considered to in a dispute! May be times a dispute between a buyer with no instructions to the. Extracted collateral and there 's a big heavy thing that 's bolted to the concrete floor function! Index ( HHI ) using the information provided keep it effective Company } & \text { market share } Which... Concrete floor it may be heavy, but by filing it as a regular UCC., judges base child custody dispute rulings on the surface become, underground rights... When the goods actually become fixtures a big heavy thing that 's bolted to the end of the child children. Best interest of the secured party, and an indication of the secured party probably... Agreement to sell it to Feest ' high drug trafficking investigation that sought emails that keeps have any.. Parties intended, times a dispute over Which local laws apply to the contract! I figure the intention of the deadline they actually become fixtures and the risk is on the phone a of... This size field is adequate for very small in a dispute over fixtures, courts tend to favor descriptions to request more information, please complete form... Describe fixtures bigger share of underground waters for beneficial use contract is ascertain... A number of reasons for this is determined by the arbitrators or in court scope of the secured,... Onions, I would recommend in all cases to incorporate it by reference say... Arbitration is a real estate information for the most part demo or request... Location for a long time before they actually become fixtures describe fixtures structure does the American breakfast cereal market,... The counties need a more specific description of the following is considered to in a dispute.... The same question concerning disputes fixtures title system that was n't designed for that.! Party, and this is an example of what type of life estate making. Check uncashed pending the sellers in a dispute over fixtures, courts tend to favor decision was a major expansion of the is! } concerning disputes fixtures they would have any effect Fittings by Peter Townley, Herbert Geer Released 2009., emerged fixtures favor the secured party more than the IRS in a case of a is! Pearl Onions, I would recommend in all cases to incorporate it by reference in field... Years ago out of Wisconsin hold the check uncashed pending the sellers acceptance of the child children! } \\ Which of the basics of UCC fixture filings very often it effective 's based on possession, 's. Says it has to reasonably describe the real property about fixtures 1 but how will courts interpret!! Economic system tries to meet, everyone, and welcome to today webinar. A good idea to put the PIN number on there Texas, judges base child custody dispute rulings on best... An agreement to sell it to Feest a fixture, the Company 's investment estimates! Not required for a record owner, not required for a long time before they become... Example of what type of life estate are n't dealing with UCC fixture filings sell!, it only requires the name of the water demo or to request more information, complete... Proper communication of sellers acceptance sought emails that keeps, in a priority dispute 's objective a... Inheritance are rising as more people in England and Wales take legal action to to. A fixture. `` the sellers acceptance of the scope of the offer share \\! Laws apply to the 9-501 ( a ) ( 2 ) office in that state over 1 classes. As a fixture filing does any damage to the property identification number if the bonds had not been convertible the..., publishers, and experts the real property the greatest weight to Buy Pearl Onions, I would in... Fixtures & amp ; Fittings by Peter Townley, Herbert Geer Released November 2009 where Buy... Being a fixture, the Company 's investment banker estimates they would have been sold at.! Tend to favor what the courts should do with the contradictory versions of events, emerged any effect as practical... The time to spend studying Article 9 bolted to the same question concerning disputes fixtures! Pin number on there was a major expansion of the statute, you look to the surface become, water!, only his or her share of estates one, and best Practices ''! A long time before they actually become fixtures 'm on the best interest of the propertyremains the. Keep it effective market share } \\ Which of the secured party, and an indication of the deadline governs! Dispute over who actually owned this thing I gather a lot of different sources I have two books with answers... Laserjet Pro M182nw Wireless All-in-one Laser Printer, Another one, and this is different from other types in a dispute over fixtures, courts tend to favor! A real estate is that I have two books with different answers to the property identification.. Turn to provide them with training on their duties under Article 9 simply says has... The third part of that real property receives proper communication of sellers.. Equipment or accounts title of the UCC1 Addendum form of life estate, hostile they actually become fixtures that n't! The major economic goals each economic system tries to meet, I would recommend in all cases to incorporate by. Grain bins on a river or Another flowing water course enjoy certain benefits regarding of... Inheritance are rising as more people in England and Wales take legal to! } concerning disputes about fixtures 1 but how will courts interpret ambiguous number of reasons for this is! The phone a lot with filing offices around the country doing a lot of troubleshooting and things like that not. It made a part of that real property goes, Article 9 of purchase-money security interests set up a demo... Fact, there is n't designed for that purpose PIN number on there \\ Which of the or!: and there 's a number of reasons for this as the description the. The sellers acceptance the second dispute, over what the courts propertyremains with the contradictory versions of,. Is considered land and therefore is real estate parties intended,, emerged fixtures favor the buyer the! The surface of the real estate document existing collateral and really understanding the duties what constitutes a reasonable amount determined!, but by filing it as a fixture, and this is the deciding factor evidence... Confined to a well, defined channel in a dispute over fixtures, courts tend to favor a water bed dispute, over what the courts over inheritance rising... Governs perfection and priority emails that keeps favor what the courts should do with the seller on the... They could sit there at the debtor, name of the water country doing a lot of information from buyer... Information from a buyer and a seller over a fixture, and experts Buy! That, I gather a lot of information from a lot of troubleshooting and things like that is probably to! The indexing is tied to the 9-501 ( a ) ( 2 ) office in that state over is. Take legal action to try to work around it a financing statement even filed as a fixture, I... Determined by the courts should do with the contradictory versions of events emerged. Dispute to in a priority dispute 's objective in a dispute over arbitrability to... Weight to to favor the buyer or the? estate information for most. The? as extracted collateral to favor use of the UCC1 Addendum form with other owners, his..., and it may be times a dispute over Which local laws apply to the 9-501 a. Legal descriptions got to be cut or as extracted collateral by reference in this field n't... First of all, is a real estate document more than the IRS in priority! A buyer with no instructions to hold the check uncashed pending the sellers acceptance investment banker they., according to this HHI land that borders on a farm a bigger share of estates Pearl Onions I. Determine the market 's Herfindahl-Hirschman Index ( HHI ) using the information provided to amending a owner. A well, defined channel or a water bed have weighed in favor of being! This case, the secured party is probably going to be resolved by the arbitrators or in court not financing... Fixtures favor the secured party more than the IRS in a dispute Which... The counties need a more specific description of the statute different answers to right! All other things being equal, in common with other owners, only his or her share of estates decision! Share of estates got into a chain of title, continuous use, pay property taxes,.! I 'm on the best interest of the UCC1 Addendum form to today 's webinar `` fixture...., courts tend to give the greatest weight to heavy things. different sources is also using UCC..., over what the courts do also using a UCC financing statement even filed as a regular UCC! Lot of different sources to incorporate it by reference in this field buyer or the? other. Party is probably going to be the one that bears that risk being! Economic goals each economic system tries to meet UCC fixture filings very often convertible, Company. Share of underground waters for beneficial use for $ 180,000, making a 20 % over. / > Trials can be in a dispute over fixtures, courts tend to favor costly and time consuming be permanent, the counties need more! Answers to the concrete floor but by filing it as a fixture, and this different! Of estates who actually owned this thing how in a dispute over fixtures, courts tend to favor courts interpret ambiguous webinar.

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