Peter Producer contacted Polly Playwright via telephone to write out a tv western script and promised over the phone that he will pay her $50,000 once she's finished. Polly did her research and wrote the tv western script all in a years time. However, once Polly completed her script and contacted Peter, Peter stated he will no longer need Polly's script and he will not be paying Polly since he doesn't need it anymore. Western movies are out and science fiction are in. Polly stated she did not care and will still drop off her script to Peter's office and requested Peter to have the $50,000 check ready. Peter explained that the agreement to pay the $50,000 must have been in writing in order for it to be enforceable. However, because the agreement was not in writing the contract can not be forced on to Peter and if Polly sues him then she will lose.

Identify two or more grounds under the statute of frauds that Peter could be relying on for his conclusion. If the case goes to court, will Peter win on either of these two grounds? Why or why not?