North Carolina Appeals Panel: Note On Will Was Not Valid Holographic Codicil

(June 14, 2017, 5:31 PM EDT) -- RALEIGH, N.C. — A North Carolina appellate panel on June 6 said a trial court erred in granting summary judgment in favor of the propounder of a will because although the decedent’s typewritten will met the requirements for a properly attested self-proving will, the record established that as a matter of law, the handwritten notation on the decedent’s will was not a valid holographic codicil where it would have been an expression of the decedent’s intention to make a future change to his will (In the Matter of the Will of James Paul Allen, No. COA16-1209, N.C. App., 2017 N.C. App. LEXIS 436)....

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