Deposit Return Dispute

have a friend who moved, and is not getting his $2000 dollar deposit back.
She said it was held for landscaping.

Fisrt off, this seems like it falls under normal wear and tear, and has nothing to do with the deposit.

He wants his money back but she has refused.

Is there anything besides small claims? how soon should a court action be filed. She is selling the house too, if that matters.

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