Agent Cannot Sign Codicil for Principal

An agent under a durable power of attorney cannot sign a testamentary document for a principal, so a codicil that is not signed at the direction of the testator is accordance with 20 Pa.C.S. 2502(3) is not valid and will be stricken from probate.  Pendergrass Will, 30 Fid.Rep.2d 430 (Montgomery O.C. 2010) (opinion by Ott, J.), app. dism’d 26 A.3d 1141 (Pa. Super. 2011).

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