In Rogers v. P-M Hunter's Ridge, LLC, 407 Md. 712, 967 A.2d 807 (2009), the location of the easements involved had been resolved at summary judgment, on the basis of the purported plain meaning of the deed language. Rogers, 407 Md. at 728. The circuit court and, on appeal, this Court, held that the deed language gave Hunter's Ridge the right to relocate the Rogerses' access to Landover Road unilaterally, despite the Rogerses' allegations that they had continuously used a particular path to reach Landover Road. Id. at 728-29. The Court of Appeals reversed, explaining that, because the easement grants in the deeds were "in general terms only, an ambiguity regarding the location of the easement exists . . . ." Id. at 732. Therefore, the matter could not be resolved at summary judgment, because "the ambiguity . . . may be resolved by reference to subsequent declarations and conduct of the parties, evidencing their intent." Id. at 734. In Rogers v. P-M Hunter's Ridge, LLC, the Rogerses owned a large tract adjoining Landover Road. In 1963, the Rogerses sold two portions of the parcel in separate conveyances to two companies, SDN and Landover Gardens. Rogers, 407 Md. at 716-17. Landover Gardens obtained the portion of the larger tract that abutted Landover Road, while SDN received a portion between the Landover Gardens parcel and the parcel retained by the Rogerses. Id. The 1963 deeds reserved easements for access to Landover Road for the grantors over both the SDN parcel and the Landover Gardens. Id. However, as the Court of Appeals explained, both easements were, in effect, general easements. The SDN Deed "permitted two alternative right of way easements for the Rogers parcel for ingress/egress to Landover Road." Id. at 719. First, "SDN could create a private road designed to connect the Rogers property with . . . the Landover Gardens Property and then onto Landover Road." Id. Or, in the alternative, "'in lieu of such private roadway,' SDN could construct a public roadway as a means of access to Landover Road or to 'an existing public roadway leading to Landover Road.'" Id. (quoting deed). The Landover Gardens Deed, on the other hand, "provided the Rogers parcel . . . with a right-of-way from the SDN property to Landover Road, over a specified location identified in a site plan." The site plan, however, "cannot be found in any records." Id. at 720. Ultimately, the SDN and Landover Gardens parcels were both purchased by a third company, Hunter's Ridge, and a dispute with the Rogerses ensued over the locations of the rights-of-way. Id. at 725-26 When the case reached the Court of Appeals, the Court explained that the "SDN Deed reserved an easement in general terms, because it created an option to set the easement either by private or by public roadway, and did not specify the easement's location." Id. at 734. Moreover, "the Landover Gardens Deed may have been a specific reservation when made, but the location of the easement became ambiguous by the unavailability of the site plan . . . ." Id. The lower courts had resolved the location dispute exclusively by interpreting the language in the deeds. The Court held this was error, vacated the judgment, and remanded the case with instructions for the trial court to determine the parties' intent. In remanding the case, the Court explained: "Evidence of subsequent conduct of the parties, including the Rogerses' alleged use of an easement and SDN's and Landover Gardens' alleged acquiescence to that use, or the easement's alleged extinction, needs to be adduced on remand of this case, in order to interpret the parties' intent." Id. at 735. An express easement can be either general or specific. Rogers, 407 Md. at 731. An easement is specific "when its location is easily discernible, such as from a metes and bounds description, a plat map, or a call."11 Id. On the other hand, "an easement is reserved in general terms, when it is clear from the intentions of the parties that an easement has been created, but without a precise location." Id. The Rogers Court elaborated, id. at 732: If ... the easement is reserved in general terms only, an ambiguity regarding the location of the easement exists, and we look to the surrounding circumstances, including subsequent agreements and conduct of parties, which may evidence the parties' intent. The Rogers Court explained that, in the context of a deed, a "call" is "'a landmark designating a property boundary.'" 407 Md. at 731 n.12 .