This article is in honor and in memory of Angela Susan Scheinberg. I was extraordinarily blessed that she was my wife. On 9/11, her life was savagely wrenched from me and from all who knew and loved her. Angela was a paradigm of kindness and integrity, and a beacon of virtue. I also honor every patriotic American murdered that day.

This article was inspired by the language in Phila. Ins. Indem. v Kendall, 197 A.D.3d 75, 79 [1st Dept 2021], wherein the First Department stated that the Court of Appeals’ precedent, Parma Tile Mosaic & Marble v Estate of Short, 87 NY2d 524 [1996], which held that the automatic imprinting by fax machine of the sender’s name at the top of each transmitted page does not satisfy the requirement that the writing be “subscribed” pursuant to the statute of frauds, is “…not controlling … the distinction between prepopulated [blocks containing counsel’s contact information at the end of the email] and retyped signatures in emails reflects a needless formality that does not reflect how law is commonly practiced today.”