(def's mem, ex.G, p.D00054). The plan administrator had discretionary authority to malee benefit determinations according to the terms of the Severance Pay Plan. 2 . The administrative record is missing Bates-stamped page D00006, on which we assume the 24-month limit is found. Defendant must supplement the administrative record with that page. 3 . Even if we do not consider the Human Resources manual as incorporated into the ERISA plan, plaintiff's promissory estoppel claim, based on her employment contract with CNA, would be barred by the statute of frauds, as her employment contract was for longer than one year and the promise on which she relied was not reduced to writing. See McInemey v. Charter Golf, Inc., 176 Ill.2d 482, 223 Ill.Dec. 911, 680 N.E.2d 1347, 1353 (1997)
holding that the statute of frauds operates even when there has been reliance on a promise holding that enforcement of the promise is not necessary to prevent injustice because there is no question that plaintiff has benefited tremendously from his purported reliance holding that despite the fact that the statute of frauds prevents enforcement of the agreement a plaintiff can recover outofpocket damages incurred in reliance on the alleged false representation holding that the statute of frauds bars a breach of contract claim based on an oral agreement to enter a future employment contract that would need to meet the statute of frauds recognizing circumstances that justify enforcement of a promise unenforceable under the statute of frauds