In December 2000, Nextel South Corporation, a communications company, contacted R.A. Clark Consulting, Ltd., an executive search firm, about finding an employment manager for Nextel's call center in Atlanta, Georgia. Over the next six months, Clark screened, evaluated, and interviewed over three hundred candidates. Clark provided Nextel over fifteen candidate summaries, including one for Dan Sax. Nextel hired Sax for the position at an annual salary of $75,000. Sax started work on June 25, 2001, took two weeks' vacation, and quit on July 31 in the middle of a project. Clark spent the next six weeks looking for a replacement, until Nextel asked Clark to stop. Clark billed Nextel for its services, but Nextel refused to pay, asserting in part that the parties had not signed an agreement. Nextel's typical agreement specified payment to an employment agency of 20 percent of an employee's annual salary. Clark filed a suit in a Georgia state court against Nextel to recover in quantum meruit.
What should Clark have to show to recover on this basis? Should the court rule in Clark's favor?