^{You are a Junior Paralegal at the firm Love, Jones & Kirk LLP. In your role, you have been tasked with representing James Construction Services Inc in a Small Claims Court matter. Your client is the Plaintiff in the matter and the Defendant is Luke Danes. Background on the case: James Construction Services Inc is owned by Joe James. Joe's company conducted a basement renovation for Mr Danes in July 2021. Prior to starting work on Mr. Danes' basement, your client provided Mr. Danes with an estimate for the work totaling $75,000. Mr. Danes was satisfied with this estimate and the parties signed a contract outlining the scope of work, the payment terms and an estimated date of completion for the work. Payment terms: Mr. Danes provided a 40% deposit ($30,000) upon signing of the contract. He then provided a further 20% deposit ($15,000) upon completion of half of the work. The remaining $30,000 was due to be paid upon completion of the work in its entirety. James Construction Services Inc completed Mr. Danes' job at the end of July 2021 and issued Mr. Danes an invoice for the remaining balance. The work was done in a good workmanship like manner and at no time did during the work did Mr. Danes inform Mr. James of any deficiencies or concerns with his company's work. Upon receiving the invoice from James Construction Services, Mr. Danes sent Mr. James an email indicating he was extremely unhappy with the work and refused to pay the remaining balance. This email did not provide any particulars about why he was unhappy with the work. Mr. James replied to Mr. Danes' email inquiring as to what he was unhappy with and offered to attend the property to discuss this issue with Mr. Danes. Mr. Danes did not reply to this email. Mr. James then attempted to call Mr. Danes on a weekly basis for the following five weeks and each time Mr. Danes sent the call to voicemail. Mr. James then contacted your firm to initiate a Small Claims Court proceeding for the remaining balance. Your firm issued a Plaintiff's Claim on September 15, 2021 which included a copy of the estimate and the contract, proof of payment of the first two installment payments, a copy of the invoice for the remaining balance, the email from Mr. Danes refusing to pay the balance with Mr. James' reply and a log of dates/times Mr. James called Mr. Danes to follow up. A Defence was then filed by Mr. Danes on September 30, 2021. In the Defence, Mr. Danes alleges that the work done by your client was deficient and that he had to spend $20,000 for another contractor to rectify the deficient work. There are no details of the deficiencies, documents, invoices, reports or photos attached as evidence to the Defence. Mr. Danes is selfrepresented. A Settlement Conference occurred on October 29, 2021 and a settlement was not reached. Your client instructed you to set the matter down for trial and a trial date is set for July 29, 2022.}

^{At trial, we will be calling the following witnesses:}

^{1. Joe James, owner of James Construction Services Inc.}

^{2. Robert Kerry, general manager and site supervisor for James Construction Services Inc.}

^{3. Graham Lite, general labourer for James Construction Services Inc.}

^{The only witness being called by the Defence is Luke Danes.}

^{Make defence witness cross examination questions.}