It is essential to the validity of a deed that there be a delivery, and the burden of proof
rests upon the party asserting delivery to establish it by a preponderance of the evidence.
To constitute a valid delivery, there must be an intent on the part of the grantor that the
deed shall operate as a muniment of title to take effect presently. No particular acts or
words are necessary to constitute the delivery of a deed; anything done by the grantor
from which it is apparent that a delivery was intended, either by words or acts, or both
combined, is sufficient.
Present intentinon to transfer and delivery are required
Some courts view delivery as evidence of intent
A deed undelivered is less likely to have been made with an intention to deliver