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Question
In 2021, Martin validly executed a formal will leaving all property to his daughter, Lena. In 2025, after a serious argument with Lena, Martin took a blank greeting card and wrote entirely by hand: "I want my cabin and fishing boat to go to my brother Theo when I die. Lena can have the rest. This is my final change." Martin signed the card at the bottom and dated it. No one witnessed the card.
Martin also kept a preprinted estate-planning worksheet on which he had written only his initials next to a box labeled "leave residue to charity." The worksheet had no signature and no handwritten description of the charity. After Martin died, Theo offered the greeting card as a codicil. Lena argued that the card was invalid because it was unwitnessed and, if the card is valid, the worksheet should also change the residue.
Assuming the state recognizes holographic wills and codicils when the signature and material portions are in the testator's handwriting, how should the court treat the greeting card and the worksheet?