Jack Tallas immigrated from Greece to the United States in 1914. He lived in Salt Lake City for nearly 70 years, during which time he achieved considerable success in business, primarily as an insurance agent and landlord. Over a period of 14 years, Peter Dementas, a close personal friend of Tallas's, rendered services to Tallas, including picking up his mail, driving him to the grocery store, and assist-ing with the management of his rental properties. One day, Tallas met with Dementas and dictated a memo-randum to him, in Greek, stating that he owed Demen-tas $ 50,000 for his help over the years. Tallas indicated in the memorandum that he would change his will to make Dementas an heir for this amount. Tallas signed the document. Tallas died seven weeks later, without having changed his will to include Dementas as an heir. He left a substantial estate. Dementas filed a claim for $50,000 with Tallas's estate. When the estate denied the claim, Dementas brought this action to enforce the contract. The estate of Tallas argued that Tallas's promise to Dementas lacked consideration and should not be enforced.