North Dakota Code § 30.1-09-13

(2-514) Contracts concerning succession
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A contract to make a will or devise, or not to revoke a will or devise, or to die intestate, if 
executed after July 1, 1975, can be established only by:
1. Provisions of a will stating material provisions of the contract;

2. An express reference in a will to a contract and extrinsic evidence proving the terms of 
the contract; or
3. A writing signed by the decedent evidencing the contract.
The execution of a joint will or mutual wills does not create a presumption of a contract not to 
revoke the will or wills.

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