In re Kimmel's Estate 278 Pa. 435, 123 A. 405 (1924) Kimmel wrote a letter to his kids George and Irvin, it said, "...if enny thing (sic) happens all the scock (sic) money in the 3 Bank liberty lones (sic) Post office stamps and my home on Horner St. goes to George, Darl & Irvin...signed, Father." He died suddenly a few hours after mailing the letter. George, Darl, and Irvin stepped forward and presented the letter to the Orphans' Court as a valid will. Other heirs objected to the document being a will. The Orphans' Court found that the document constituted a valid will. The other heirs appealed. The document was considered a holographic will. Holographic wills are informal, handwritten wills. In order to be a valid holographic will under the common law, it must have: A date, a signature, the intent for it to be a will, and it must be completely in the handwriting of the decedent. The Pennsylvania Supreme Court affirmed and found that this was a valid will. The Court looked to the testamentary intent of the letter, and found that it was intended to be a will. Specifically the words, "if enny thing happens." "The difficulty in ascertaining the writer's intent, arises largely from the fact that he had little, if any, knowledge of either law, punctuation, or grammar." The Court looked to the language and found that it could not have possibly meant anything other than a testamentary gift. The Court looked to the Wills Act, which requires that all wills be signed in order to be enforceable, and decided that Kimmel's will had been signed. He signed it 'Father', as opposed to using 'Harry A. Kimmel'. The Court found that the purpose of the signature requirement was to make sure that the will wasn't fraudulent. Therefore any signature was acceptable. Some illiterate people sign with an 'X'. The Court found that the intent to execute was apparent.