Reference no: EM133214793

Fact Scenario:

1. Walter M., "Materials by Walt" provided various construction materials like concrete to contractors. He was very prompt in providing the materials as he knew that the construction industry was working very hard in the summer to complete their jobs.
2. Walter M. provided concrete to "Sidewalks by Susan" a Construction company and invoiced her on May 5, 2017. She kept saying "don't worry, Walt, I'll pay. Just give me two more months. " Walt called, left messages, emailed and tried to get his money. She owed him $10,000.00. He was even being very reasonable and allowing her to pay in instalments. But nothing. He started dropping over at her construction site, but still nothing. You had evidence of all of these attempts to get Susan to pay, all calls, emails and texts.
3. On May 25, 2022 he hired you, a Paralegal, from "Punk Paralegals" to sue her. You were happy to help but realized there might be a problem. You drafted filed and served the claim.
4. Susan's Paralegal, Henry, filled out a defence. He would have written some of the following main points:

Draft a sample defence and include legislation that Henry would have referred to.