The Statute of Frauds requires that an agreement be in writing if by its terms performance is "not to be completed before the end of a lifetime" (Personal Property Law, § 31, subd. 1). Had the Legislature intended the "lifetime" referred to to be the lifetime of the promisor, the party to be charged, or the lifetime of any particular person, it could easily and readily have so provided. (See 4 Ariz...
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