I. Introduction

II. Background … A. Holographic Wills and Codicils ... B. Construction vs. Interpretation of Wills ... C. Nebraska's Position Regarding the Handwritten Alteration of an Attested Will

III. Analysis ... A. Altered Holographic Wills vs. Printed Will Forms ... B. The Nebraska Probate Code's Requirement that the Material Provisions of a Holographic Will Be in the Handwriting of the Testator ... C. The Nebraska Supreme Court's Requirement That Ms. Foxley's Words Alone Must Establish Intent ... D. Ms. Foxley's Intent and the Circumstances Surrounding Her at the Time She Altered Her Attested Will ... E. The Unstated Concern That the Absence of Witnesses Casts Doubt on Whether Ms. Foxley Had Testamentary Intent When She Made Handwritten Alterations to Her Attested Will ... F. The Effect of Foxley on Holographs in Nebraska

IV. Conclusion