Wolfe v. Wolfe

In this appeal, we consider whether a letter written by a testator to his executor reflects the requisite testamentary intent to qualify as a valid codicil to his will.

In 1982, Jared D. Wolfe executed a will disposing of his property. Ten years later, on April 29, 1992, he wrote a letter in which he stated “I want my daughters to share Vs, Vs, VL” On May 14, 1992, Jared committed suicide. Kathleen Wolfe, Jared’s former wife and executor of his estate, submitted the will for probate but declined to offer the letter for probate. A hearing was held pursuant to an inter-party probate order to…