Estate of Norton
Supreme Court of North Carolina
410 S.E.2d 484 (1991)
Norton's unsigned six-page document, ending mid-sentence with no witness signatures, was later stapled together with a properly executed two-page codicil under a cover sheet titled "Will of Lawrence Norton and Codicil to the Will of Lawrence Norton," all placed in his safety deposit box alongside an unrelated, separately incomplete earlier codicil; a jury found the six-page document was properly incorporated by reference into the codicil, but the trial court entered judgment notwithstanding the verdict finding it was not, a ruling the court of appeals affirmed and Norton's daughter Teab (plaintiff) appealed.
Whether a document may be incorporated by reference into a properly executed will or document, if the language of the will does not clearly identify the document that is to be incorporated.