Zhao v. Wong

The decedent, Tai-Kin Wong, lived with his girlfriend, Xi Zhao. After his death, a handwritten, dated, and initialed document was found in his office reading All Tai-Kin Wong's with an arrow pointing to Xi Zhao, my best half. Xi (plaintiff) sought to probate the document as a holographic will; Tai's father (defendant) objected, arguing the words were insufficient and there was no showing of testamentary intent. The trial court admitted the document as a holographic will and held the entire estate passed to Xi. Tai's father appealed.

Whether a handwritten document can be admitted as a holographic will when it contains no words describing property or expressing testamentary intent.