In Chang v. Lederman (2009) 172 Cal.App.4th 67, the decedent and Ms. Chang lived together for several years before marrying. The decedent, who had been diagnosed with terminal cancer, retained an attorney to prepare a revocable trust approximately six months before he married Ms. Chang. The executed trust provided for distributions of $ 30,000 and some personal property to Ms. Chang and $ 10,000 to another individual; Ms. Chang was to vacate the residence within 30 days of the decedent's death; and the property was to be sold or leased for fair market rent. The residue of the trust estate was left to the decedent's only child. A first amendment to the trust, executed a month later, reduced the sum to be distributed to Ms. Chang, eliminated the distribution to the other individual, and expressly left all other provisions of the trust unchanged. During that same period, the decedent executed a will to dispose of property he owned in Israel. After his marriage to Ms. Chang, the decedent executed a second will in Israel which apparently did not provide for her in any way and did not expressly revoke the trust, as amended. Then, five or six months after the marriage, when the decedent was seriously ill, he instructed the attorney to revise his trust to leave the entire trust estate to Ms. Chang, with the understanding that she would give the decedent's son $ 250,000 when he turned 25. The attorney refused and told the decedent that if he modified the trust, the decedent would be sued by the successor trustee. The attorney also advised that the decedent should have a psychiatric evaluation before making changes to his estate plan. The decedent died a few weeks later without making any further amendments to his trust. After the will and trust were held valid, Ms. Chang sued the attorney for professional negligence, breach of fiduciary duty, and intentional infliction of emotional distress. The court found no duty to Ms. Chang, who was only a potential beneficiary, not an expressly named beneficiary of an express bequest. "The difficulty ... is that any disappointed potential beneficiary--even a total stranger to the testator--could make factual allegations similar in most respects to those in the second amended complaint; and, without requiring an explicit manifestation of the testator's intentions, the existence of a duty--a legal question--would always turn on the resolution of disputed facts and could never be decided as a matter of law." (Chang v. Lederman, supra, 172 Cal.App.4th at p. 83.) The court thus concluded that it would place an undue burden on the profession to hold that estate planners owe a duty of care to unnamed potential beneficiaries. "Without a finite, objective limit on the identity of individuals to whom they owe a duty of care, the burden on lawyers preparing wills and trusts would be intolerable." (Id. at p. 84.) In short, an expressly named beneficiary attempted to assert a legal malpractice claim not on the grounds of her actual bequest, but based on an allegation the testator intended to revise his or her estate plan to increase that bequest and would have done so but for the attorney's negligence. (Chang, supra, at pp. 74, 86.) The Court of Appeal concluded that "a testator's attorney owes no duty to . . . an expressly named beneficiary who attempts to assert a legal malpractice claim not on the ground her actual bequest . . . was improperly perfected but based on an allegation the testator intended to revise his or her estate plan to increase that bequest and would have done so but for the attorney's negligence." (Id. at p. 86.)