(noting that creation of an agency does not require any formalities). Where the agency relationship concerns an interest in real property, it must be evidenced by a writing conferring such authority to satisfy the statute of frauds. 28 V.I.C. § 241. Here, Watson acted as Bennett’s agent in redeeming the property. Redemption does not create any rights or interest in property. See UMLIC VP, LLC v. T & M Sales & Envtl. Sys., Inc., 176 S.W.3d 595, 606 (Tex. App. 2005) (“Unlike the purchase of real property, redemption does not establish new title; it restores the parties to the position they were in before the lien.”). As such, an agency relationship to redeem real property does not fall within the statute of frauds. See, e.g., In re W.H. Shipman, Ltd., 84 Haw. 360, 934 P.2d 1, 9 (1997) (<HOLDING>). While conceding that Watson came to the Court
recognizing that water rights constitute a real property interest holding that because property was no longer property of the estate the court could not order turnover holding that forfeiture of real property may be adjudicated before the seizure occurs because real property cannot abscond holding that because no real property interest was transferred to the agent by virtue of her redeeming the property the statute of frauds was inapplicable holding that plaintiffs may have a property interest in real property