15

Footnote 15

A paper signature identifies the signed matter less than perfectly. Ordinarily, the signature appears below what is signed, and the physical dimensions of the paper and the regular layout of the text are relied upon to indicate alteration. However, those mechanisms are not enough to prevent difficult factual questions from arising. See, e.g., Citizens Nat'l Bank of Downers Grove v. Morman, 78 Ill. App. 3d 1037, 398 N.E.2d 49 (1979); Newell v. Edwards, 7 N.C. App. 650, 173 S.E.2d 504 (1970); Zions First Nat'l Bank v. Rocky Mountain Irrigation, Inc., 795 P.2d 658, 660-63 (Utah 1990); Lembo v. Federici, 62 Wash. 2d 972, 385 P.2d 312 (1963).