Claude Labont operates an earthmoving and excavation business in the Beauce region. He is being sued by his neighbor's insurer for having damaged the land

Claude Labonté operates an earthmoving and excavation business in the Beauce region. He is being sued by his neighbor's insurer for having damaged the land of the single-family home of his insured Roger Huot, while he was carrying out excavation work on the neighboring land. The insurer alleges that the deterioration of the land is manifested by an accumulation of rainwater at the bottom of Roger Huot's land, which damaged his in-ground swimming pool. Cracks appeared inside and outside the pool. An expert report, commissioned by Mr. Huot's insurer, demonstrates serious breaches of the rules of the art in carrying out the work. These deficiencies are at the origin of the damage to Roger Huot's land.

 what should be the article which grounds the appeal of Roger Huot's insurer against Claude Labonté?

If Claude Labonté's company is a joint stock company, who should be prosecuted? Claude or his company?

What must be demonstrated for the appeal against Claude Labonté to be successful?