Consumer Protection Law
Consumer Protection Law Questions? Ask a Lawyer Now.
You want to answer the complaint denying the claims. Obviously, he cannot collect, since he was paid what was agreed and he has no contractual basis years later to get more. The court will dismiss. You can go on the offensive too, by adding counterclaim to your answer seeking damages from him for the bad work done and expenses you incurred including money back you paid.
You have a defense of waiver, breach of contract, unclean hands.
You can answer with such defenses, or move to dismiss.
His failure to perform, leaving the job, waiting so long each alone is a defense - and together are a very good response to the baseless complaint.
Kindly rate the answer as excellent.