I see. Thank you for providing this additional information, Paul.
First, the statute of limitations for a breach of contract claim under NJ law is typically 6 years, so that does not appear to be a valid defense for you since he has filed the suit within that period of time since he alleges you breached the contract.
Oral agreements are normally enforceable, but the issue typically involves being able to prove the terms of such agreements, including the value of the work performed and materials supplied.
If the contractor cannot prove the extent of the work he performed or materials supplied and cannot prove what you agreed to, then he would likely have a very weak case.
Since you have arrived at a figure of $50,000 based on the writings that are available, that would typically be a reasonable figure for a court to use as well unless the contractor is able to submit other proof.
Assuming there is no other proof as you have indicated, I would not anticipate a judgment for the amount the contractor is seeking, but closer to the offer you have made.
Legal expenses could mount though, so I would try to press for mediation
if at all possible.
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