64.04.020. Under the statute of frauds, such contracts are unenforceable unless they are set forth in writing and signed by the party to be bound. Family Med. Bldg., Inc. v. State, Dept of Soc. & Health Servs., 104 Wn.2d 105, 702 P.2d For internal use only SDNY_GM_00056922 CONFIDENTIAL - PURSUANT TO FED