Welcome! My goal is to do my very best to understand your situation and to provide a full and complete answer for you.
Good morning. The first thing you want to do is get an estimate from a competent painter as to what it will cost you to complete the job properly. If that's less than $1200, you would only be willing to pay the fired painter the $1200 reduced by the cost of having someone else finish; if it will cost more than $1200 to complete, you don't want to pay the fired painter another dime but instead would want the painter to pay you the excess amount needed. What you will want to do is raise the stakes on him so that he knows that not complying with your demands is going to cost him far more in the end than simply settling with you based on your demand. You should send him a certified, return receipt requested letter detailing the history and demanding that he agree to settle this on the terms you demand within a short specified period of time. Inform him that if your demand is not timely complied with, you will have no choice but to file a suit against him for your damages
. Be sure to specifically mention that you will be filing this claim not only as a breach of contract case, but also as deceptive trade practice and fraud actions, which will entitle you not only to your damages, but also an additional amount equal to multiple times your actual damages as punitive damages. That should provide plenty of incentive to comply with your demands; but, if it does not, file your suit. As part of this, you will want to have him sign a Settlement and Release agreement before any money is paid. I can provide you a template for such a document if you need it...just let me know.
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