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The Statute of Frauds applies to any settlement agreement requiring a transfer of an interest in real property. See, e.g., Nicholson v. Barab, 233 Cal. App. 3d 1671, 285 Cal. Rptr. 441, 447-49 (Cal. Ct. App. 1991) (holding that the Statute of Frauds applies to parol judicially supervised settlement agreements requiring the transfer of an interest in real property); Perimeter Inv., Inc. v. Amerifirst Dev. Co., 423 So. 2d 586, 587 (Fla. Dist. Ct. App. 1982) (holding that the Statute of Frauds applies to parol settlement agreements requiring the transfer of an interest in real property); Ogden v. Griffith, 149 Idaho 489, 236 P.3d 1249, 1253 (Idaho 2010) (applying the Statute of Frauds to a settlement agreement that called for a deed of trust but concluding that equitable estoppel permitted enforcement of the agreement); Schmidt v. White, 43 S.W.3d 871, 874 (Mo. Ct. App. 2001) (holding that a settlement agreement involving the transfer of an interest in real property is subject to the Statute of Frauds); Omaha Nat'l Bank of Omaha v. Mullenax, 211 Neb. 830, 320 N.W.2d 755, 758 (Neb. 1982) ('An alleged oral compromise and settlement agreement [involving a transfer of an ...

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