Assignment of Royalties Did not Include Subsurface Property Interest

Assignment of royalty interests did not convey subsurface mineral interests (which the corporate executor of the New York estate did not realize the decedent had retained) because the language of the assignment was unambiguous and without mistake, and so summary judgment was appropriate to quiet title in the estate.  Estate of Roswell Miller v. Miller Associates, 3 Fid. Rep. 3d 170 (C.P. Westmoreland 2012) (Opinion by Marzili, J.)

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