Aladdin and Gene entered into an oral agreement wherein Aladdin was to purchase from Gene a parcel of land on which he planned to build a home. After Aladdin paid half the purchase price, Gene granted him permission to access the land. With Gene's permission, Aladdin also hired a company to begin pouring the foundation for her home, which they immediately began. One month later, on the date scheduled for closing, when Aladdin requested the title documents, Gene refused to convey them. Can Gene use the Statute of Frauds as a defense to this contract? Explain fully.