Bogle & Gates, P.L.L.C. v. Zapel

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 *446satisfy the writing requirement for purposes of the six-year statute. Because the three-year statute for oral agreements applied to bar the firm’s contract claim, we vacate the award of summary judgment and remand for further proceedings.

FACTS

This case differs from Bogle…