Derek Moran
You are rushing-off to court without exhausting the private-administrative-Notice-process as a remedy first.....if it were me, id start off with an AFFIDAVIT FOR PROMISSORY ESTOPPEL ARISING FROM DETRIMENTAL RELIANCE, and tell your story in point-form, how he said one thing, did another, and how he's now trying to screw you because of it, because you RELIED upon his representations to you were in good faith - again, thats what I would do