Note Or Memorandum
The Cyclopedic Law Dictionary · Walter A. Shumaker and George Foster Longsdorf; ed. James C. Cahill · 1922
The Cyclopedic Law Dictionary
No form of language used in a writing is necessary in order to comply with the Statute of Frauds, requiring some "note or memorandum" as evidence of a contract not in writing, provided that from the writing the intention may be gathered, and any writing from a solemn deed down to hasty notes or memoranda in books, papers, or letters will satisfy the statute, provided that the writing contains on its face or by reference to other writings, the names of the parties, a description of the property, sufficient for its identification, together with the terms, conditions and consideration.
209 111. 478.