BOGLE & GATES, P.L.L.C. v. ZAPEL

No. 51876-3-I.

90 P.3d 703 (2004)

121 Wash.App. 444

BOGLE & GATES, P.L.L.C., a Washington professional limited liability company, Respondents, v. John ZAPEL, an individual, Appellant.

Court of Appeals of Washington, Division 1.

May 3, 2004.


Attorney(s) appearing for the Case

Frank R. Siderius, Siderius Longergan & Martin, Sea., WA., for Appellant.

Michael A. Goldfarb, Law Office of Michael Goldfarb, Sea., WA., for Respondents.


GROSSE, J.

Ex parte writings may bring a contract within the six-year statute of limitations if they contain all the elements of a contract, including the promise of the party to be charged. Here, a law firm's retention letter, which confirmed an oral agreement, did not express a promise by the firm's client, and thus the letter did not satisfy the writing requirement for purposes of the six-year statute. Because the three-year statute for oral agreements applied...

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