Most courts reject the part performance doctrine as an avenue for avoidance of the statute of frauds in the employment context. Courts have recognized in other circumstances that a promisor's acceptance of partial performance may estop a defense under the statute on the ground of equitable fraud. Northeast Inv. Co. v. Leisure Living Communities, Inc., 351 A.2d 845, 855 (Me. 1976); McGuire v. Murray, 107 Me. 108, 115 (1910). Under this doctrine, too, the focus has been upon the conduct of the promisor. Moreover, an employee's preparations to begin a new assignment generally convey no direct benefit to an employer so it is particularly inappropriate to remove from an employer the protections of the statute. An employee can recover for services actually performed in quantum meruit. But to enforce a multi-year employment contract an employee must produce a writing that satisfies the statute of frauds or must prove fraud on the part of the employer.