Connecticut Appellate Court Holds That Alleged Oral Modification of Loan Agreement Violated Statute of Frauds

In Deutsche Bank Trust Company Americas, Trustee v. DeGennaro (April 29, 2014), the Connecticut Appellate Court rejected a borrower's claim that a purported oral modification of a loan agreement should have precluded summary judgment, instead finding that the Statute of Frauds precluded such a claim and that the payment of a preexisting obligation (i.e., a mortgage) does not constitute adequate consideration.

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