Mr. Grove is a business man. He has lots of contracts that he deals with in his life. Read each of the following scenarios. Decide which ones must be in writing because of the statute of frauds. Explain why each contract is covered by the statute of frauds or why it is not. These should be short answers, two or three sentences.

Mr. Grove's father dies after winning a lemon eating contest. He leaves debts on his lemon grove, including pay for his workers who had to pick a whole lot of lemons in the days before his death. Mr. Grove feels bad and promises to pay all of them for their work, even though the estate does not have enough money.