The following excerpt is from Van Horne v. Campbell, 100 N.Y. 287, 3 N.E. 316 (N.Y. 1885):
It was objected to these cases that they all referred to personal estate. But upon this question I confess myself unable to see the distinction between cases relating to personal property and cases relating to real estate.
And then, after referring to Gulliver v. Vaux and other cases, he continued:
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