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The statute of frauds does not require a written contract; a “note or memorandum … subscribed by the party to be charged” is adequate. (Civ. Code, § 1624, subd. (a).)Civil Code section 1624, subdivision (a) states:“The following contracts are invalid, unless they, or some note or memorandum thereof, are in writing and subscribed by the party to be charged or by the party's agent.” Subdivision (a)(3) of section 1624 includes agreements for the sale of real property.


This discussion does not apply to any other “statute of frauds” imposing a stricter writing requirement. (Rest.2d Contracts, § 131, com. a, p. 334; see, e.g., Fam. Code, § 852 [transmutation agreements involving separate and community property; In re Marriage of Benson (2005) 36 Cal.4th 1096, 1108-1109 [32 Cal. Rptr. 3d 471, 116 P.3d 1152]]; Fam. Code, § 1611 [premarital agreements; In re Marriage of Shaban (2001) 88 Cal.App.4th 398, 405 [105 Cal. Rptr. 2d 863]]; Civ. Code, § 1803.1 et seq. [retail installment contracts].) Nor does it govern the more liberal statute of frauds provided in the California Uniform Commercial Code. (Cal. U. Com. Code, § 2201; see Cal. Code com., 23A pt. 1 West's Ann. Cal. U. ...

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