Written by Jeremiah J. Moffit, Esq.,* Courtney A. Sorensen, Esq.* Craig S. Weinstein, Esq.*, and Sara Z. May, Esq.*
I. TRUST AMENDMENT SIGNED AND ACCEPTED BY SETTLORS, BUT NOT NOTARIZED, WAS INVALID UNDER TRUST PROVISION REQUIRING NOTARIZATION
Balistreri v. Balistreri (2022) 75 Cal.App.5th 511, review granted
The First District Court of Appeal held that when a trust specifies a method of amendment, Probate Code section 15402 provides no basis for validating an amendment that did not comply with that method, regardless of whether the method of amendment is exclusive or permissive.