We agree with the IAS Court that the three-sentence transmittal letter sent by defendant Forest City's building manager to defendant Utility Programs, more than two years after the purported contract was entered into, does not constitute a memorandum of that contract sufficient to bind Forest City, since the letter does not show the intent to authenticate the contract necessary to comply with the Statute of Frauds (General Obligations Law § 5-701 [a] [1]; Scheck v...
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