William J. Jenack Estate Appraisers and Auctioneers, Inc., Appellant, v Albert Rabizadeh, Respondent., 22 N.Y.3d 470

Summary

ISSUE: Whether a sale of an auction item to an absentee bidder was memorialized in a writing that satisfied General Obligations Law § 5-701(a)(6). HOLDINGS: [1]-A clerking sheet, on its face and in isolation, did not satisfy the statute because the statute required disclosure of the buyer's name and the name of "the person on whose account the sale was made," and inserting numbers in place of those names did not meet this requirement, as it did not provide for an alternative to a name; [2]-"Related writings" supplied the required names because an absentee bidder form, with the clerking sheet, established the buyer's name, each document contained required information pertaining to the sale terms, as both contained an item number, bidder number, auctioneer, and the item's description, and the clerking sheet listed the auctioneer, who was the seller's agent.