1. Cosmo Kramer has an express easement across Jerry Seinfelds property that Kramer uses as a right of way to reach a public road. In which of the following circumstances has the easement been terminated by estoppel?

1. Kramer starts occasionally using a shorter right of way across a portion of Newmans property to access the public road.

2. Kramer signs a written document agreeing to extinguish the easement.

3. There is a giant landslide on Jerrys property that destroys the right of way.

4. Kramer tells Jerry that he no longer will be using the right of way, and Jerry builds a swimming pool where the right of way used to be.