Countervail livery
Black's Law Dictionary · Henry Campbell Black, M.A. · 1910
Black's Law Dictionary
At common law, a release was a form of transfer of real estate where some right to it existed in one person but the actual possession was in another; and the possession in such case was said to "countervail livery," that is, it; supplied the place of and rendered unnecessary the open and notorious delivery of possession required in other cases.
Miller v. Emans, 19 N. Y. 387.