Question: Percy Fairchild bought a one-acre homesite in the country, on which he planned to build a home and enjoy a "gentleman's farm" with an extensive garden and a variety of animals. In connection with the purchase, he acquired a standard policy of title insurance. Thereafter, he began leveling the land for a foundation for his home and outbuildings. He promptly was served with a lawsuit in which a neighbor to the rear, Georgette Simpson, was the plaintiff. Simpson alleged that she owned an easement (right to use) across the middle of Fairchild's lot because she had used it for 15 years for access to the county road. She requested the court to enjoin the construction to protect her easement. Fairchild asked his lawyer to cross-complain against the title insurance company for the apparent defect in his title. Will he win?