Massachusetts courts have several times ruled that access easements may be recognized even though language creating an express easement may be missing or ambiguous in the deeds to the servient estate. Hickey v. Pathways Ass'n, 37 N.E.3d 1003 (Mass. 2015) (access easement recognized over registered land even though it is not in the certificate of title to servient estates when mention of it appears in titles to the dominant estates and maps indicating the easement were recorded at the registry and available to the servient estate owners before purchase); Reagan v. Brissey, 844 N.E.2d 672 (Mass. 2006) (right to use lots as parks found from recorded map). See also Loiselle v. Hickey, 107 N.E.3d 1205 (Mass. App. Ct. 2018); Leahy v. Graveline, 971 N.E.2d 307 (Mass App. Ct. 2012) (both interpreting ambiguous recorded maps and deeds to determine if neighboring owners have access easements).