Solid716

information from attorney should be there very soon

This letter will serve as a response to the above-referenced Revdex.com (hereinafter"BBS") ComplaintMrC*** retained me and my firm with respect to the pre-litigation demandmade by Ms*** regarding the renovation work to her bathroom (hereinafter "the Project") forwhich she retained my clientSignificantly, Ms***'s attorney, Ronald *** H*** Esq., demanded$15,in a letter to my client dated July 21, Following that letter, I responded to MrH*** in aletter dated August 18, 2016, and requested information to substantiate Ms***'s allegationsMr.Hart responded in a letter dated September 2016, and provided me with an estimate of costs,which amounted to $18,Subsequently, Ms*** filed the Revdex.com Complaint that is the subject ofthis responseMs*** now seeks $21,000!Ms*** maintains that she needed to have her whole bathroom gutted after the work wascompleted by my clientIt is unfathomable how that is possible in light of the work completed by myclient, as evidenced in the attached photographsThe photographs of the work speak to the qualityof my client's efforts and work-productThe real issue is not my client's work-product, but rather thatMs*** continued to change her mind mid-way through the Project, resulting in delays to theProject and additional expense to my clientMs*** alleges that she needed to gut and herentire bathroomThat was her decision alone; it is not based on any culpability of my clientMy clientincurred significant expenses, which he is still owed due to Ms***'s continual revisions to theProjectMy client is not responsible for any damages or expenses to Ms*** and will not incurthe expense of her unnecessary choice to gut her bathroom.As a threshold matter, it is worth noting that the work my client completed was not under Solid 716LLC; rather, the work was done in his individual name.The FroiectMs*** retained my client for the purposes of a custom renovation of her bathroom after havinginitial discussions about what she wanted, which occurred in March of During severalmeetings, my client discussed the Project with Ms*** and conducted an assessment of theexisting bathroomFollowing the assessment, my client prepared and created a 3-D design, whichincluded researching materials and products to showcase, creating schematics and layouts, andscheduling and coordinating the ProjectMy client presented the design to Ms*** to begintailoring the Project and transitionFollowing that presentation, my client re-designed the Project inlight of revisions made by Ms***In early April of 2016, Ms*** approved the final renderingand design of the ProjectThe work on the Project began immediately thereafterMy client quotedMs*** $12,for the workAs with any construction project, particularly a custom one, eventsarise that may result in delay or additional expenseHere, the constant revisions by Ms***BUFFALO I CORNING I ERIE PA I NEWYORK I ROCHESTER ISYRACUSENovember 2, 2016Page 2caused both delay and additional expense, which were magnified due to ongoing schedulingconflictsTo further demonstrate my client's work and the Project, enclosed you will find before andafter photographs, as well as a timeline of events.The Project began quite smoothly, with my client and his contractors working diligently to completethe Project in a timely fashionNotablyMs*** does not raise any issue about the timeliness ofthe ProjectRather, her sole complaint is the alleged "shoddy workmanship" by my clientThephotographs depict the before and after of the ProjectThose photographs will demonstrate that myclient's efforts and work-product were anything but "shoddy."Ms***'s Alleged Damages and Demand for the SameMs*** is seeking reimbursement and replacementNotwithstanding that my client denies anyresponsibility, reimbursement and replacement would result In an excessive windfall for Ms***and she is not legally entitled to those damagesMoreover, the three amounts demonstrate that Ms.*** seeks damages that exceed what she actually paidThat notwithstanding, at this junctureIhave not yet seen any proof of payment or invoices for any of the amounts sought by Ms***; Ihave seen only estimatesCertainly, if Ms*** seeks reimbursement, those payments andinvoices exist and the same should be provided to allow for a thorough analysis of whether suchwork was necessaryMoreover, those invoices would clarify what amount of damages Ms*** isseeking.ConclusionMy client went above and beyond the contract to please Ms***He continued to revise theProject, the materials, and work requested by Ms*** to make her "happy." Thephotographs of my client's work speak volumes as to his abilities and craft, and the aliegation thathis work was "shoddy" is unsubstantiated and offensiveIt is unfortunate that Ms*** continued tochange her mind about the Project; however, those revisions and changes by Ms*** are notattributable to my client's alleged "shoddy work" and do not reflect any fault of hisMy clientmaintains a stellar reputation for his work and creativity in the community and he wishes that itremains that way.Up until receiving the BBS Complaint, we were dealing directly with MrH*** Ms***'s attorney.We will continue to do so in an attempt to resolve this matter and will await word from the BBS withrespect to this complaintWe are prepared to supplement our response, if necessary, and want thismatter to be favorably resolved without any negative impact on my client, as the evidence indicateshis work was proper.Very truly yours.*** *** *** *** ***

This letter will serve as a second response to the above-referenced Revdex.com(hereinafter "BBS") Complaint based on the November 9, 2016, reply from Ms, ***.Ms***'s November 9, 2016, reply re-alleges items already addressed in her original complaint,which I addressed in my response dated November 2, In her reply, Ms*** noted that shehas a contractor writing up why the work she either sought to have completed or actually hadcompleted was necessaryFurthermore, Ms*** staled that she will provide photographs andcontractsWe await all of that informationAt this juncture, Ms*** has not substantiated herclaims with anything more than purported estimates, which we have been unable to confirm and myclient maintains are unnecessary.To the extent Ms*** contended that her contractor stated that my client used impropermaterials, we deny such an allegation and are prepared to obtain supporting evidence to refute suchan allegation, should that be necessarySimilarly, my client maintains that he explained the entireproject to Ms***, which included the creation and demonstration of 3-D sketchesShe was fullyaware of the progress of the Project and made frequent and significant revisions as the Projectcontinued.Significantly, after providing three separate damages calculations, Ms*** maintains, wrongly,that she is entitled to $21,for reimbursement and replacement costsNotwithstanding that weawait Ms***'s submission of information from her contractor along with the other materials listedabove, even if my client was responsible for what Ms*** alleges is "shoddy workmanship,"which he is not, Ms***'s claim for damages would provide her with a substantial windfall, whichshe is not entitled to under the law.Thank you for your attention to the above matter.Very truly yours,*** *** *** *** ***

unfortunately when I met with Jonathan C***, the contractor, to discuss my complaints he took the contract with him When I called for it to be returned he claimed it was in his truck and could not find it As a senior I do not know how to email the notes I have from the meeting in
which I outlined my concerns and he did sign my written concerns according to the contractI can mail the papers to you

My new contractor is in the process of writing up why they had to gut the shower and floorMrC*** did not put the proper material in the shower before applying the cementThe walls were damaged when he removed the wallpaperThe showere door was damaged by him as well He never presented any dimensional drawings I have a computer printout and that is all I will respond to each of his claims and send pictures and contracts

Business's attorney called and stated that they are not in litigation and the business will not be giving any refund Nothing was his fault and he made multiple change and this consumer is just not going to be satisfied with anything If this does go to court, the business with be counter claiming

As for the threshold matter of whether your client, MrC***, was working under Solid 716LLC, please note that all correspondence and emails were sent from his company's email addressand signed "Creative Director"Also, please note that my clientMrs***, visited Solid 716LLC twice to do businessHe also sent her a bill on a Solid LLC invoice.My client has submitted the following narrative and pictures to prove the; allegations relative tothe work MrC*** performed at her homeMrC*** was hired to renovate my client'sbathroomEnclosed are pictures prior to MrC*** {See "Before Pictures", Exhibits A-C) andthe condition the bathroom was in when MrC*** completed the job and decided he could nolonger please Mrs***(See "After Pictures" Exhibits D-M) MrC*** never presenteddrawings, nor did he ever provide schematics and layouts of how he was going to tackle thisprojectAll he submitted was Exhibit N and Exhibit O.DAMAGE TO WALLSAs per damages to the walls, your client was called and told that the wal paper lot did not match.He insisted on the wallpaper being hung anyway and claimed that he would fix itThe wallswere in pristine condition before the wallpaper was hungThe walls got damaged when yourclient removed the vinyl wall paper and he tried to fix the damagesHe Ijiad several additionalworkers come in and try to fix the damage, but to no avail.DAMAGE TO BOXESAs per damages to the boxes, they were totally destroyedThe drawers \t'ere made of wood andmy client only wanted a different finish on the boxes so cleaning would be easierThe boxeswere destroyed to the extent that they would not open properlyMrC*** sent a carpenter tomy client's home twice because the first time he misplaced them on the wallA couple of them*** *** *** *** *** *** ** *** *** *** *** *** *** *** ** *** *** *** ** ** *** *** *** ***were put on the wall backwards(See Exhibits P-Vemails from your client discussing andadmitting damages)DAMAGE TO THE SHOWERThe concrete that was applied over the tile came off the walls very easilyThe contractor statedthat the drywall work was done very sloppily, unprofessionally, and that the concrete was notcorrectly applied to the wall: in some areas, it was not even adhered to the wallThe concretethat was removed from the walls literally weighed a tonThe shower floor was not trainedcorrectly; moreover, the pitch was not correct which in turn left water standing.ATTEMPT TO REMEDY PROBLEMSOn June MrC***Mrs*** and her daughter Beth ***Esqsat down anddiscussed the outstanding problems with the bathroomMrs*** and MrC*** signed andagreed to remedy the issues and complete the project by FridayJuly 1, At that time thebalance of $1,would be paid to MrC***HoweverMrC*** chose to stop workingon the bathroom, claiming that it was impossible to satisfy Mrs*** when, in fact, he realizedthat it was impossible for him to fix the damages that he created(See Exhibit W)Finally, see attached images of the condition MrC*** left Mrs***'s bathroom.After MrC*** quit, Mrs*** contacted licensed contractors to repair the damagesAllthree said they would not be associated with the work that had been done, and they would haveto totally gut the entire bathroom because the concrete was improperly applied and the wallswere extremely damagedAttached, please find the signed proposal and contract from thelicensed contractor as well as expenditures for materials, etcto date(See Exhibits X and Y)If we do not receive a satisfactory response to this letter from your clientMs*** intends tofile a lawsuit for the damages she sustained hereinI expect to hear fromjyou within five (5)business daysThank you in advance for your prompt attention to this matter.Sincerely yours,*** ** ***cc: Via Certified Mail: *** *** *** *** *** * *Revdex.comBryant WoodsSouthAmherst.NY 14228RE: Complaint

I retained the attorney first.We are not in litigation yetI am waiting for my signed contracts on work being done to fix the bathroom which we will forward to you and his attorney