Beckley, the'chancellor found Tewksbury, supra, persuasive. We agree that Beckley is not on all fours but, for thé reasons explained in the text, do not find Tewksbury’s limited discussion of the standing issue persuasive. 10 . As described above (see supra ¶ 24), this CD was surrendered in 2008, and its proceeds were invested in a new CD that was surrendered in 2009. The combined proceeds of that CD and another CD were then in part invested in a new CD, which still existed at the time of trial, and in part deposited in Elva Mae’s checking account. Thus, identification of the funds "attributable to” the original CD presumably would have required some additional calculations by the parties or the chancery court. ’ • 11 . See also Huston, 51 Cal.App.4th at 1727, 60 Cal.Rptr.2d 217 (<HOLDING>). 12 . ''[W]here a joint tenancy account in a
holding that a principal cannot ratify a gift that violated the express terms of a pda without executing a written ratification or written modification of the attorneyinfacts authority under the poa holding that the use of the written form is mandatory and that failure to use the written form as mandated is reversible error holding that an alleged oral modification of a written employment agreement was not enforceable because the employees action in remaining on the job did not constitute adequate consideration holding that the erroneous use of the term burglary in the beginning of the written jury instructions was not fundamental because any error was cured by the correct use of the term theft in the latter portion of the written instructions recognizing that deference to an agencys interpretation of the written law is appropriate only when that interpretation is within the written laws language