Tony Lenoy Strange brought a declaratory judgment action seeking a ruling that he was the sole trustee of his mother Pauline’s inter vivos trust. After Pauline’s 2011 trust amendment named Tony and two relatives as successor co-trustees, she signed a July 2012 durable power of attorney stating that Tony should serve as executor of her estate and the trust and had full ownership pursuant to her final wishes. Pauline later died, and the trial court rejected Tony’s claim that the document validly revised the trust. The Court of Appeals of Georgia reversed. The trust expressly reserved Pauline’s power to amend, and OCGA § 53-12-40 required only a written instrument signed by the settlor. The trial court therefore erred in finding the power of attorney invalid because of notarization; the notary’s identifying stamp satisfied the governing statute. The document also unambiguously showed Pauline’s intent to modify the trust, despite her use of “executor” and “revoke,” because it identified Tony as the person with full ownership and Georgia law treats a power to revoke as including a power to modify. Pauline’s later letter asking the law firm to update the trust did not undo the completed written modification. The judgment was reversed.