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Good morning. I certainly understand the situation and your concern. It is important to know that the Judge will grant a motion for summary judgment, when there is no genuine issue of material fact. As such, a motion in opposition to their motion for summary judgment needs to be filed with supporting affidavits, to show the Judge that there is an issue and it needs to be decided at trial. You want to address and oppose their claims which they are asking the Judge to grant the SJ and clearly show there is a legitimate dispute about this.
You would want to attack their claim that there was a written agreement. You want to show what the elements are for a valid contract and show those are not present and that you have evidence which contradicts their claim that you owe X. You shared above that there was a proposal and if so, it should have had amounts on it and that is what was relied on.
You can always have a counter claim, so that should have been filed when they filed suit against you. Moreover, if they previously alleged there was no contract and that was the basis for them prevailing, they can not come back now and allege there was, so you would want to show the Judge this.
If you could not perfect your appeal as a result of the heart attack, there would be good cause present, to try and vacate that ruling. It should have been done timely ( once you knew about this and recovered), so you would need to explain the reason for the delay. Now, if you wanted to file a counter claim, you likely would need permission to amend your answer and file the counter claim, so it relates back to the original filing.
Your motion in opposition to their summary judgment should include facts and evidence to show why it should not be granted. If your appeal was denied as a result of you being in the hospital and failing to respond, that is a separate issue.
Please let me know if there is anything else, as I would be happy to respond. If not, please remember to rate my help at this time at the top of this page, prior to leaving, so I can receive the proper credit, for our time together. Thank you.