A deed which is executed and delivered as an escrow cannot take effect as a deed pending the performance of the condition subject to which it was so delivered1. However, once a deed is delivered as an escrow, it may not be recalled2. A document that has been validly executed as a deed requires delivery to take effect, and execution of a deed does not demonstrate an intention to deliver the deed in escrow3. The unilateral action of the landlord in delivering the lease in escrow followed by the fulfilment of the escrow condition is not, however, to be
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