In Crook v. Contreras (2002) 95 Cal.App.4th 1194, a marital trust became irrevocable upon the death of one of the two spouses who established the trust. Following the death of one of the spouses, the surviving spouse, Florence, nonetheless attempted to name a new beneficiary of the family trust. In finding Florence had no power to make such a change, the trial court stated: "Under California law, the existence or nonexistence of a right to revoke must be determined by examining the trust instrument and determining from language used in the instrument whether the settlors intended in 1988 when the trust was created to confer on Florence a right to revoke Trust A after her husband's death." ( Crook, supra, 95 Cal.App.4th at p. 1209.) The Court considered whether two documents complied with the witnessing requirements of section 6110 and therefore qualified as codicils. It was undisputed that both witnesses saw the testator sign the documents, but only one witness signed the documents at or about the time of their execution. Two years after the first document was executed, a year and a half after the second document was executed, and a month after the death of the testator, both witnesses signed witness attestations. Finding no California law on point, the court looked to cases from other jurisdictions rejecting postdeath subscription of a will, and was "unpersuaded that we should chart a new course. Our independent construction of Probate Code section 6110, in light of its legislative history, discloses no indication that the Legislature intended by its 1983 statutory revision to permit postdeath subscription of a will. A conclusion otherwise would attribute to the Legislature an intent to allow the validity of a will to depend upon the will or caprice of one who had been requested to perform the very simple act of becoming a witness by allowing such a person to wait until after the testator's death to decide whether or not to subscribe his or her signature to the will. Such an interpretation would invite fraud and subvert the basic intent of will authentication requirements. We conclude that the subscription of a will by two witnesses must occur prior to the testator's death, and a will that has not been subscribed by two witnesses at the time of the testator's death neither complies nor substantially complies with Probate Code section 6110." (Crook v. Contreras, supra, 95 Cal.App.4th at p. 1205.)