1. The Williston "plain meaning" school limits contract interpretation to the four corners of a written agreement.
2. Under the Corbin approach, extrinsic evidence is admissible only if a party makes a preliminary showing that an agreement is ambiguous.
3. The <i>PG&E</i> court held that it is improper to interpret a contract without the benefit of extrinsic evidence of the circumstances surrounding the inception of the agreement.
4. The Corbin approach to contract interpretation advocates that what initially appears to be plain and clear language may be shown to be ambiguous in light of the circumstances surrounding the agreement at the time it was entered.
5. California's extrinsic evidence rule is solely a common law development.
6. Some courts have questioned the wisdom of the <i>PG&E/Corbin</i> approach.
7. Even after provisionally considering extrinsic evidence that is offered, a court may decline to admit that evidence.
8. <i>PG&E</i> permits preliminary consideration of extrinsic evidence that is offered, but allows it to be stricken or discounted if, rather than clarifying the meaning of the contract, the evidence adds to or varies the terms of the contract.
9. In the decades since <i>PG&E</i>'s extrinsic evidence rule was announced, many cases have followed the rule rather than suggesting it should be abandoned.
10. California cases have held that the intent of the parties is to be ascertained, if possible, from the written provisions of the contract.
11. If a trial court admits evidence that does not support an interpretation to which a contract is reasonably susceptible, the court's decision will likely be reversed on appeal.
12. Extrinsic evidence is especially likely to be admitted when offered to interpret a choice of law clause in an international contract.
13. In 2006, the California Supreme Court retreated from the rule in <i>PG&E</i> when it decided <i>Dore v. Arnold Worldwide, Inc.</i> (9 Cal. 4th 384 (2006).)
14. Extrinsic evidence is never admissible to interpret a contract governed by the statute of frauds.
15. <i>PG&E</i> and <i>Corbin</i> consider the judge's experience a form of extrinsic evidence.
16. Oliver Wendell Holmes was an adherent to the Corbin theory.
17. Under <i>PG&E</i>, courts may properly exclude extrinsic evidence.
18. Court decisions have recognized that insurance-industry testimony and drafting-industry history can be useful as extrinsic evidence.
19. The Ninth Circuit has staunchly supported the decision and reasoning of <i>PG&E</i> since that case was decided.
20. Under <i>PG& E</i>, if the court concludes that a contract’s language is reasonably susceptible to either of two proposed interpretations, extrinsic evidence must be considered in construing the contract to determine its meaning.