I have been doing collections work for 22 years, and this is not an unusual scenario. The defendants accepted my clients' services, and never complained about the quality of workmanship until they were asked to pay for the services. Their defense usually falls apart on cross examination. When they testify that there was a problem with the services, you question them on the details...what was the problem....exactly how many times did you experience this problem...did you complain to the plaintiff....on exactly what dates did you complain...to which of the plaintiff's employees did the defendant complain...were the complaints oral or written...if written where are they now...did these alleged service problems cause large problems for the defendant (undoubtedly they will say yes)...and in all this time why did the defendant not think to put the complaint is writing if the problems were so serious...did the defendant continue to accept services after the initial date on which they claim the problem arose.When they can not substantiate the defense with any detail...it becomes nothing more than a general statement that lacks credibility.

By the time you get done with cross examining on the details, the judge usually sees through the defense as a pretext, and it is judgment for the Plaintiff.