Oral Agreement to Form Entities to Buy Real Property Not Subject to Statute of Frauds

On April 12, 2016, the First Department issued a decision in Retter v. Zyskind, 2016 NY Slip Op. 02742, holding an alleged oral agreement was not subject to the statute of frauds, explaining:

Where, as here, plaintiff alleged an oral joint venture agreement to form entities that would, among other things, acquire real property, the agreement is not subject to the statute of frauds.

(Internal quotations and citations omitted) (emphasis added).