Washington Appeals Court Disallows the Use of Extrinsic Evidence in Dispute Over a Will On November 4th, 2019, the Court of Appeals, Division I for the State of Washington overturned a trial court’s decision in a dispute over an allegedly ambiguous will. The case—In re Matter of the Estate of Earl M. Holmes—involved a Washington man named Earl Holmes whose will disinherited his relatives. Mr. Holmes Disinherited Relatives—But Failed More