In Gray v. Goodrich (7 Johns. 95 [Sup Ct, NY County 1810]), the court found that the admission of testimony about a statement made by a deceased person who was a witness to the disputed horse sale was reversible error. The court relied on the absence of the oath: "This evidence was clearly inadmissible. The law requires the sanction of an oath to all parol testimony." (Id. at 96.) The exceptions were pedigree, prescription and custom, and the deceased who spoke being under oath or in extremis.