There is, however, a statutory exception to this general rule. Under New York law, [a] promise in writing and signed by the promisor or by his agent shall not be denied effect as a valid contractual obligation on the ground that consideration for the promise is past or executed, if the consideration is expressed in the writing and is proved to have been given or performed and would be a .valid consideration but for the time when it was given or performed. N.Y. Gen. Oblig. Law. § 5-1105. “To meet § 5-1105’s requirement that the consideration be 'expressed’ in the writing,, the recitation of consideration must not be vague or imprecise.” Genger v. Genger, 76 F.Supp.3d 488, 498 (S.D.N.Y.2015); see also Umscheid v. Simnacher, 106 A.D.2d 380, 482 N.Y.S.2d 295, 297-98 (2d Dep’t 1984) (<HOLDING>). Here, the district court correctly held that
holding that a statute is not vague where the words themselves  possess a common and generally accepted meaning holding that consideration was not expressed within the meaning of section 51105 where it was vague imprecise and indeed  without meaning holding that the complaint stated a claim under the flsa where it alleged that parties were an employer and employees within meaning of act and that the defendantemployers operation constitutes an enterprise engaged in commerce  within the meaning of  the act holding that a state is not a person within the meaning of  1983 holding that a police department is not a person within the meaning of section 1983