Estate of Berger

Holding

The court held that, notwithstanding the lack of two witnesses, a California probate court may consider extrinsic evidence of the circumstances surrounding a document’s execution even when the document’s language unambiguously expresses testamentary intent, and that the totality of the evidence in this case satisfied the clear‑and‑convincing‑evidence standard required by Probate Code § 6110(c)(2) to treat Melanie P. Berger’s 2002 letter as a valid will. ---