Do Copies of Medical Exam Brochure, Completed Application and Fee Receipt Constitute a 'Written Contract?'

Where Lawsuit Asserts Claim For Breach of 'Written Contract or Promise'

Mohamed Bassem Rayess v. Educational Commission for Foreign Medical Graduates, Case no. 2011-1933

Second District Court of Appeals (Montgomery County)

ISSUE: In order to invoke the 15-year limitations period (time limit) for a plaintiff to bring a lawsuit based on breach of a written contract or promise, may a plaintiff meet the requirement of producing a copy of the written contract by submitting a combination of documents including an informational brochure describing a medical test, a copy of the plaintiff's application to take that test, cancelled checks for the testing fees, and supplemental correspondence between the applicant and the testing authority?