California small claims court question

[Matt Hadley]

California landlord. Tenant is suing in small claims court for full security deposit plus damages. He rented my house. I agreed to end his lease early because I wanted to move back in early. Everything was by email or text. I have withheld his entire deposit.

First, he is stating we didn't tell him of his right to an initial inspection and that's bad faith. I said by email we would do a walk-through on the day he vacated, and we did a walk-through that day before he turned over the keys. The place when I went on the last day was filthy and I told him so. He said to take it out of his deposit.

Second, he is stating we didn't give him an itemized list with receipts within 21 days of vacancy. I did email an itemized list to him on the 16th day but did not send receipts. I hadn't lined everything up so I estimated some costs including repainting and replacing the carpet. He sent a demand letter after 21 days and I set an email back a week later (28 days after vacancy) with estimates for the carpet replacement, which are way more than what I billed him for in my first email. I don't have receipts for the services to clean the house he left so filthy, but I sent my writeups of those services in my second email.

Third, he is stating I didn't prove my carpet or paint had any remaining useful life. I don't have receipts for the carpet, but he ruined it. I had taken good care of it and I wasn't planning to replace it for another six years. And he put stickers on the wall for his kid, so I had to repaint the chips and that's like $400. I don't have receipts but the carpet was fine and it needed to be replaced in full.

Fourth, he is stating I acted in bad faith by doing these three things, plus how i responded to him in my second email. I did state all of the deductions I could have taken in my first email and told him I could have deducted a lot more. And I also said that I might sue for those additional deductions if he sued me, which is my right. He said that's intimidation and that I manufactured the expenses in my second email, just because i didn't mention them in my first itemized list.

So we are going to small-claims court and he wants the entire deposit plus damages. How much should I countersue him for?