The Honey Do Service

Relative to the complaint filed, it is important to note some facts that are not listed within the complaint: A summery is listed at top with supporting details below.
Summery:
I. Duplex has two addresses as contractor states, not only one, as clients claims.
II. No verbal, or written contract for both apartments has ever existed.
III. The client demonstrated disorganization and confusion during the process which created multiple difficulties and can be verified by third party sources.
IV. Contractor has made many attempts to help client (extra repairs not on proposal but requested by client, reduction of costs, in materials and labor to keep project running, and offers to help with addition free labor under certain conditions)
V. The client's payment history indicates a different narrative than he is now claiming.
VI. In the meeting attended on April 1st, the client admitted his mistake in assuming both sides were to be done even thought it was not part of the agreement. But even with that true, he was unwilling to come to a reasonable solution for a situation of his making.

Details Description:
I. Duplex has two addresses as contractor states, not only one as clients claims.
A. The duplex has two addresses assigned to it . Although the client insists *** is the sole address.
II. No verbal, on written contract for both apartments has ever existed.
a. Although the client initially set up the estimate appointment for , he switched sites at the last minute and requested that I work on .
b. The estimate tour we both performed on *** was highly detailed and listed on the working proposal.
c. *** apartment was never shown to me by him or the then current resident. I never entered or performed any sort of evaluative analysis or estimate for that apartment. In 35 years, I have never written an estimate for over $300 without myself or a representative of mine completing an estimating tour.
d. There is no agreement written, verbal, or otherwise made by me to perform services on both sides.
e. The working proposal emailed to the client had only the address of *** because that is the site originally requested. But he instructed me to list services for *** and never signed the corrected document left for him at my office. And he has no full contract document on either side, only the working proposal emailed the him for revisions.
III. The client demonstrated disorganization and confusion during the process which created multiple difficulties and can be verified by third party sources.
a. He called for an estimate on 1628 but had us perform the diagnostic estimation on .
b. That estimation was delayed because he did not have a key and attempted a forced entry into the apartment assuring me the apartment was empty. The resident approached us from inside very angry because he still lived there. This required a reschedule on the requested estimate of 1630.
c. He did say several times that he only had $30K to do the job and I assured him just the repairs to *** and some exterior repairs would be significantly more than that.
d. I informed him that the best approach was to list what I could do and he then could make the decision to proceed or not. For example, He requested that all window in the building be replaced with the $30k amount. When I informed him, I could not replace all the windows in the building within the cost of $30K, he seemed frustrated and insisted we try to do it for the $30K. I told him it was not possible. He accepted that reality and encouraged me to move forward with the project.
e. He failed to have power turned on for the first week of work.
f. He committed to but failed to have septic tank and HVA work in a time for the contractor to complete sequential work in a timely manner. (Can be verified by current resident)
g. There was a week and a half period where I requested a meeting through calls and texts to which he was unwilling to committee (phone history evidence available) The meeting was requested to discuss the financial situation we were dealing with as a number of additional issued created cost over runs. I also needed him to sign the contract.
h. He also twice confronted my employees creating a hostile environment and caused them to leave
i. These accumulative events made it very difficult to complete the job in a timely manner.
IV. Contractor has made many attempts to help client (working w/o client's written commitment, extra repairs, reducing costs, of materials and labor to keep project running, and offers to help with addition free labor under curtain conditions)
a. Worked pressed on because I believe he was acting in good faith but was generally overwhelmed and disorganized.
b. Accommodations were made throughout the process. To meet his budget, I removed all surcharges for material and subcontractor labor to the amount of $3500.00. The client was only charged for raw material subcontractor costs.
c. I also reduced my labor cost by 14% in an effort to meet his financial restrictions. Both of these actions were taken due to additional renovation needs of the apartment which were not determined until primary demolition had occurred.
d. The total cost overage absorbed by me to complete the project in good faith totaled $5K (supported with evidence of receipts, subcontracts and hourly timesheets).
V. The client's payment history indicates a different narrative than he is now claiming. From the prospective one the "one side" proposal, the Client has paid 84% of proposal, with 95% of *** apartment and 90% of the exterior complete. But, with the "both sides" argument, he now claims he has paid 84% of less than 50% of project. Why would he make the last two $5000 payments if that were true.

VII. In the meeting attended on April 1st, the client admitted his mistake in assuming both sides were to be done, even thought it was not part of the agreement. But even with that true, he was unwilling to come to a reasonable solution for a situation of his making.
a. When the meeting was finally attended on the first of April, he verbally admitted that he thought he made a mistake and misunderstood the agreement. He even shared that he had spoken to his wife about past occurrences such as this, and she said "He makes mistakes like this all the time because he doesn't listen."
b. But then He insisted it was part of the agreement, even if he had been confused, I should have known the difference and been prepared to do the work. I then pointed out, that (a) At no point, had I committed to doing both sides, (b) there was not written much less sighed contract for both sides, (c)the working proposal listed only one side and, only listed specific actions to one side.
c. He asked if I could just understand that it was just a mistake and just fix it. I told him could not afford to make up for his confusion, but I would try to help under some conditions. He refused, stating he would not pay me for the work that was completed, until I had completely remodeled the other side for free. I responded saying that was too much to ask even if it was a honest mistake.
d. Also during the meeting, I informed the cleint that only a final walk through of the apartment was needed to create a punch list of any final repairs, and completion of some siding work on the exterior. I requested that the client pay for all work completed to date, holding out funds for the siding and the punch list until those were completed within the next 24 hours. The client then informed me that he had no intention of paying any more money until the other side had been completely renovated as well. I informed the client that would be impossible and wasn't part of the agreement.
e. I did try to offer assistance, but his request to help him cover the entire cost from this mistake was not financially feasible. I told him that if he was willing to pay me for the work I had completed up to that point, I would help him with the labor for the flooring next door, if he bought the material. Once again, he refused and said he would only pay when I had completed the total renovation for the other side at no additional cost. That is where we parted ways. I informed him that, when he was willing to meet reasonably, I would be willing to help.