Must An Assignment Be In Writing?

Lawyers are sometimes asked to render an opinion that "the [bill of sale] is sufficient as to form to transfer the Company's right, title and interest in and to the assets specified in the Agreement to the Buyer".   Implicit in this opinion request is an assumption that a bill of sale must conform to some specific form.  That assumption, however, is at odds with Section 1052 of the California Civil Code which provides: "A transfer may be made without writing, in every case in which a writing is not expressly required by statute".  As the Court of Appeal has explained: