Hatch v. Riggs National Bank

MEMORANDUM

SIRICA, District Judge.

Plaintiff, settlor and life beneficiary of an irrevocable trust, seeks to modify its terms. 1 Such trusts may be modified provided the settlor and all beneficiaries consent. 2 The heirs of the settlor comprise the remaining beneficiaries. 3 Plaintiff cannot obtain the consent of all the beneficiaries because her heirs cannot be ascertained until her death. At an earlier point in this litigation plaintiff sought to obtain relief by arguing that, applying the doctrine of worthier title, she was the settlor and sole beneficiary, and therefore the terms of the…