On May 1, 2000 Peters C.P.A. entered into an oral contract with Dell to provide certain accounting services to Dell for $150/hour "to be completed within 10 months." The contract was fully performed by both parties by July of 2000. On April 25, 2020 Dell commenced a breach of contract action against Peter claiming Peter had improperly performed the accounting services. Peter's best defense to the action would likely be the:

And why?

a. Parol Evidence Rule

b. Statute of Limitations

c. Lack of Consideration

d. Statute of Frauds