Speedy Trucking Inc. and Trailer Rents LLC are parties to an oral agreement for a one-year lease of six doublewides with payments totaling more than $40,000. They may satisfy the Statute of Frauds by
a. mutually agreeing not to commit fraud.
b. repeating the terms in a phone call.
c. shaking hands on the deal.
d. setting out the terms in a memo.