1. what are the ideas and possibilities can use as possible objections in this case below if we are indefendant side?
2. how we can make the rules of the small claims and rules of civil procedure open also to quote rules?

Schedule A

1.The Plaintiff, Mr. York, claims:

a.$35,000.00

b.Pre-judgment interest starting August 1, 2021, as per the Courts of Justice Act

c.His costs of this action; and

d.Such further and other relief as this Honourable Court deems just.

2.Mr. York resides at 32 Dundas Street in London Ontario.

3.Mega Contracting (defendant), resides at 167 Central Ave in London Ontario.

4.On April 10, 2021: Mr. York contacted Mega Contracting company.

5.Mr. York's desires of this renovation were:

a.Build a staircase and to add a basement entrance to the property.

b.Build a retaining wall.

c.Install glass door.

d.Install a railing for the basement stairs.

e.Install a motion light.

6.On April 20, 2021, Mr. Moon and Mr. York had an oral agreement and agreed to have

the basement renovations begin on June 1, 2021.

7.On May 18, 2021, Mr. York had paid $14,500.00 to the Mega Contracting Company via

cheque.

8.On June 1, 2021, construction began with a set completion day of August 1, 2021.

9.On June 15, 2021, Mr. York contacted a landscaping company and was given a contract

to begin landscaping to fix the property.

10.On June 28, 2021, Mr. York met with Mr. Moon to discuss how the renovations were

progressing. Mr. Moon assured Mr. York that they were still on track for the August 1,

2021 completion date.

11.Mr. York expressed with Mr. Moon that we wanted to be consistently updated on the

work and timeline.

12.On July 2, 2021, Mr. York had paid an additional $2,951.00 to Galway Greens

Landscaping Inc for re-grading and re-sodding his property following the renovations by

Mr. Moon.

13.On July 15, 2021, the city building inspector, Mr. Norman, showed up to complete a

routine inspection, examining safety protocol and permits.

14.Mr. Norman discovered that safety protocols had not been met and that Mega Contracting

did not have proper permits.

15.On July 19, 2021, Mr. York was contacted by Mr. Norman and was informed that Mr.

Moon did not have permits due and was not following safety protocols. Due to this, a

stop-work order was issued by the city.

16.Mr. York had tried to contact Mr. Moon immediately about the conversation he had with

Mr. Norman in regards to the stop-work order.

17.Mr. York was unable to get a hold of anyone at Mega Contracting. He left a voicemail.

18.On July 23, 2021, Mr. York reached out via telephone to Mega Contracting and Mr.

Moon again. Again, there was no answer and Mr. York left another voicemail.

19.The August 1, 2021 completion date came and went and the job remained incomplete.

20.There was no further communication from Mega Contracting or Mr. Moon from the

initial voicemail left on July 19, 2021.

21.On August 20, 2021, Mr. York contacted DTF Design-Build and Renovations for a quote

to complete the renovations.

22.On August 21, 2021, DTF Designs and Build Renovations gave Mr. York a quote of

$16,000.00 for their services in the completion of the renovations.

23.Liquidated Damages:

a.$14,500.00 paid to Mega Contracting/ Mr. Moon

b.$2,951.00 paid to Galway Green's Landscaping Inc.

c.$1,549.00 Waste removal

d.$16,000.00 for DTF Designs and Build Renovations

Exhibits Attached

A.Job site photos

1.The backside of the house prior to construction;

2.Raw excavation, prior to installation of the stairs and retaining wall

3.Retaining wall and staircase structure form;

4.Destruction of the backyard;

5.Destruction of the backyard;

6.Destruction of the backyard;

7.A truck filled with garbage, left on-site by Mr. Moon.

B.Receipt from the waste removal company totalling $1,549.00

C.Cheque payable to Galway Greens Landscaping Inc. in the amount of $2,951.00

D.Cheque made payable to Mr. Moon, in the amount of $14,500.00

E.Quote from DTF Designs for the correction of improper renovations and completion of

renovations.

F.Stop-work order issued by the Building Inspector, Mr. Newman.

Break Down of Costs:

Mega Contracting: $14,500.00

build a staircase

build a retaining wall

installation of a glass door

installation of a railing

installation of a motion light

permits

materials

general labour

New contracting company (DTF): $16,000.00

evaluation of damage and corrections needed;

correction of improper installation of retaining wall;

correction of improper installation of basement door entrance and staircase;

completion of basement staircase and entrance with the door;

completion of retaining wall;

installation of a railing for the basement staircase;

installation of a motion light;

payment for permits and licensing needed.

Landscaping company: $ 2,951.00

level the ground

sod

labour

Disposal fees: $ 1,549.00

Waste left on-site by Mega Contracting

TOTAL : $35,000.00