Simon v. Grayson
Supreme Court of California
102 P.2d 1081 (1940)
Relevant factsFree
The testator's will directed $4,000 be distributed to executors as instructed in a letter dated March 25, 1932, and a later codicil reaffirmed that provision without changing it; no letter dated March 25, 1932 was ever found, but a July 3, 1933 letter addressed to the executors, referencing the same $4,000 will provision and directing payment to Esther Cohn, was discovered in the testator's safe deposit box.
IssueFree
Whether a document found among a testator's belongings that resembles, but does not exactly match, the document described in the will may be incorporated by reference despite the discrepancy, if it appears to be the referenced document and existed when the will was republished by codicil.