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Crabtree v. Elizabeth Arden Sales Corp – Case Brief Summary (New York)

In Crabtree v. Elizabeth Arden Sales Corp., 305 NY 48 (1953), which concerned an employment contract, the Court of Appeals held that in the context of the statute of frauds, a series of signed and unsigned writings may be read together, providing they clearly refer to the same subject matter or transaction, so as to form a contract (305 NY at 55).

As Judge Fuld explained, the statute of frauds allows a contract to be "'pieced together out of separate writings, connected with one another either expressly or by the internal evidence of subject matter and occasion.'" (Id. at 54.)