The ONLY access to Tom's land is across Steve's land. Which of the following is necessary in order for Tom to have an Implied Easement of Necessity across Steve's land?
a) Tom must actually live there on Tom's land.
b) There must be Apparent Prior Use of Tom's ingress and egress.
c) Tom must have a license issued by Steve to cross Steve's land.
d) Tom's land must have been created by the subdivision of Steve's land.