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Document summary:
VIRGINIA - Utsch v. Utsch, 28 Va. App. 450, 565 S.E.2d 345 2002) A deed of gift conveying separate property into joint names is not conclusive proof of a gift to the marital estate. The parol evidence rule does not bar the admission of evidence suggesting a lack of true donative intent. But the form of the deed is some relevant evidence that such donative intent existed.
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