Ramey (plaintiff) executed an escrow to sell the subject property. The escrow described the land as follows: “The west 160 feet of that part . . . of the following described property: . . . except road.” Arizona Title Insurance and Trust Company (Arizona Title) (defendant) drafted a deed which contained the following description: “The west 160 feet of the following described property as measured at right angles from the Easterly right of way line of Central Avenue . . . except any portion thereof lying within Central Avenue.” The Superior Court of Maricopa County granted summary judgment in favor of Arizona Title and held that the escrow instructions and the deed described the same property. Ramsey appealed.