Burdette v. Brush Mountain Estates, LLC, 278 Va. 286 (Va. Sup. Ct. 2009)

(statute requiring estates in land be conveyed by deed or will inapplicable to conveyance of easement (easement is not an "estate"); but deeds at issue along with plat which was incorporated for descriptive purposes did not contain operative words manifesting an intent to grant an easement).