Which of the following is most likely to be deemed a promise made in consideration of marriage that must be in writing to be enforceable under the statute of frauds?

a$.$ Jake, a multimillionaire, proposes to marry Paige, a $25-$year old golfing sensation and swimsuit model, who promptly rejects him. Jake then pleads with Paige that if she marries him, he will give her an island he owns off the coast of California. Paige begins to see Jake in a different light, and accepts his offer.

b$.$ Marc and Candy have been married for eight years and have two young boys. Marc asks Candy if she will allow him to travel to Las Vegas for the weekend to spend time with his college buddies, and Candy agrees.

c$.$ Mike and Aimee have been married for $20$ years, and Mike has had enough. Mike suggests to Aimee that if they get divorced, Mike will let Aimee keep the house and the cars, as long as she promises not to sue him. Aimee agrees.

d$.$ None of the above contracts must be in writing to be enforceable, because purely verbal agreements are valid in each case.