The trust grantor hired an attorney for assistance in making changes to his trust. The grantor also served as trustee of his revocable trust. He handwrote interlineations on the trust document and sent it to his attorney along with a signed adhesive note describing what he sent. The grantor died before the attorney drafted a trust amendment. After the grantor’s death, the successor trustee petitioned the court for instructions, asserting that the interlineations did NOT amend the trust. The trial court granted summary judgment to the trustee and the court of appeals affirmed. The trust document required amendments by written instrument be signed by the grantor. The interlineations were not signed and the signature on the adhesive note was not a signature of the new instrument. Pena v. Dey, 252 Cal. Rptr. 3d 265 (Cal. Ct. App. 2019).