Vague and Undated Codicil

Decedent executed a will in 1996, consisting of 9 words, date, and signature leaving everything to his mother.  Following his death, another document is found consisting of 12 words (“At the time of my death, the house goes to Sandy Munro”), which is signed but undated, and mother appeals from probate.  Court finds that the additional document is a codicil and that the house refers to the only home or real estate the decedent owned, because decedent and Sandy did not know each other until 2003, meaning the putative codicil was drafted after the will and not vice versa.  Basner Will, 4 Fid. Rep. 3d 375 (OC Chest. 2014) (Opinion by Tunnell, J.)

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