Tennessee_Lien_Law_Summary.pdf

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TENNESSE MECHANICS LIEN LAWWith Changes Made in 2010

Section ContentsPre-lien Notice(s)

Name of Notice

Who Must Use This Notice

When

How to Serve

Verified or notarized?

Page 1 of 162010. NationalLienLaw.com. All rights reserved. (925) 899-8449. [email protected]. Revised 12-10

Section ContentsMechanics Lien

Who is Entitled to a Lien?

When to File/Record

Where to File/Record

How to Serve

Amount of Lien

Property Subject to the Lien

Furnishing Information

Verified or Notarized

Priorities

Lien Release Bond

Miscellaneous Issues

Section ContentsLawsuit to Foreclose Lien

Introduction

When

Where to File Arbitration

Need a Lawyer?


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General Notes

Be Careful: The courts consider a mechanic=s lien to be a privilege and not aright. You receive its benefits only if you strictly adhere to thestate law requirements. Bottom line: miss a deadline by one dayand you have lost it. Unlike other areas of the law where you canargue equities, find technical exceptions, and lawful excuses, there

is no forgiveness here. In this case, knowledge is not only power,it=s a necessity.

This means in Tennessee you will be writing down dates for at least fivedocuments: a) Notice to Owner (general only); b) Notice of Lien and SwornStatement (the mechanics lien which applies to the general, subs, andsuppliers); c) Notice of Nonpayment (subcontractors and suppliers only); d)Sworn Affidavit to Owner (general only); and e) Lawsuit to Foreclose theMechanics Lien. Write down all the deadlines in your calendar. Use ahighlighter or red pen. If you have a staff, use a Afail safe@ system by doubling upand putting it in their calendar also. This reminds you twice. The first calendar

entry should be two weeks before the due date as a preliminary reminder.

On the second calendar entry, do a white lie to yourself. Put the due dateas one week before it is actually due as insurance in case you get busy or needlegal advice.

Time is money. You will waste a lot of valuable time running around anddoing it at the last moment, as opposed to doing it early.

NOTICE TO OWNER

State law defines a general contractor (as of 2007, they are referred to asprime contractors in the lien statutes) as a person, other than a materialman orlaborer, who has a direct contract with the owneras a contractor or constructionmanager. Thus, persons licensed either as prime contractors or subcontractorsare within this classification if there is a direct contract with the owner or agent.The requirement of serving a Notice to Owner applies only to a prime contractor(in this summary, references to a general contractor or prime contractor are oneand the same).

Is the Notice

Required? State law Section 66-11-206 states the Notice shall beserved on the owner, which is the legislatures way ofindicating it is mandatory. However, the same statute makesit clear the failure to serve will not prevent a generalcontractor, subcontractor, or supplier from later enforcingtheir mechanics lien. On the other hand, if you fail to serve


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the Notice and a subcontractor or supplier later files amechanics lien, it is a misdemeanor.

The purpose of the Notice is to give the owner a warningthat mechanics liens can be filed against the property, thatthey should expect to receive a pre-lien notice from subs,

and most importantly that an owner is exposed to the dangerof paying twice if they do not take steps to protectthemselves. In other words, if the Notice has not beenserved, an owner may not know their rights and fail to takesteps (lien waivers, joint checks, etc.), resulting in paying thegeneral the entire amount under the contract and ifpayments do not filter through to the subs, subcontractorscan file a mechanics lien. The net effect is the owner mayend up paying twice.

Unfortunately, many general contractors overlook the service

of this Notice, especially since it must be sent out before thework commences. Even though it is uncertain whether youwill be prosecuted for a misdemeanor, it is still a good idea inthe eyes of the court to do so. Remember that judges in thisarea of the law expect you to strictly comply with themechanics lien laws and it only makes you look bad later incourt when you fail to do so.

There is also an added benefit in serving it--the owner hasthree days after receipt to reject the contract. If it does not, itsimply confirms to an even greater degree that you are

authorized to do the work.

When?: See Time Deadlines table. Before starting work or signingthe contract.

How to Serve: There had been some uncertainly before the new laws of2007 as to how notices in general could be served. Undernew section 66-11-149, notices can be served by any of thefollowing means (all notices can be served in this manner):

1) Certified mail. Service is complete within threebusiness days of mailing.

2) Hand delivery (too expensive since you need a swornand notarized statement that it had been served, or aprocess server). Service is complete on receipt.


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3) Overnight delivery (UPS, FedX, etc.). Service iscomplete within one business day after delivery.

Form and

Content: The notice must be in writing. State law pre-determines itscontent and you must include certain mandatory language.Because of this, by far the best approach is to use a standardform so you do not leave out the required information. To havethis form prepared now online, see the list of forms at the end ofthis section.

The Effect of

the Notice: On non-residential projects, the effect of the notice is thatsubcontractors and suppliers can file their mechanics liens eventhough the owner has made full payment to the generalcontractor. In other words, in cases in which the money does notfilter down to those persons. That is because the owner is notified

of the presence of the subs and suppliers and can take steps tomake sure they are paid. The owner has an escape clause inthat they have 3 days after receipt of the notice to cancel anycontract, but if not done so within that time period, the right ofrejection is waived.

WHO IS ENTITLED TO A MECHANICS LIEN?

Tennessee severely limits the rights to record a mechanics lien onresidential property. A residential project is defined as one in which there are 4or fewer dwelling units on a parcel of real estate, in which the owner lives in one

of the units as that persons principal place of residence. Only generalcontractors can record mechanics liens on residential property. All otherpersons, including subcontractors and suppliers, are forbidden from doing so.But there is an exception: If the owner and general contractor are one in thesame person (the owner acts as his or her own contractor and deals directly withthe subs), then subs and suppliers who have a direct contract with the owner canfile a lien.

PRELIEN NOTICE

This state requires a Notice be sent out before the mechanic=s lien is

filed/recorded. For simplicity, this notice will be referred to as a APrelien [email protected] basic information on this Notice is as follows:

Name of Noti ce: Notice of Nonpayment (Commercial Projects only).


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Who Must Use

this Notice: All contractors, subcontractors, laborers, andmaterial/equipment suppliers who do not have a directcontract with the owner or the owner=s agent.For example, a general contractor with a direct verbal orwritten contract with the owner who acts as the prime is notrequired to give the Notice. As of 2007, all such persons are

referred to as remote contractors under the statute, asomewhat unfortunate description.

As stated above, subcontractors and suppliers who dealthrough a prime contractor do not get any lien on residentialproperty and do not have to serve this Notice.

When: See Time Deadlines table. Within 90 days (not threemonths) after the end of the month in which the constructionservices or materials were last provided and not been paid.This notice must be given each month in which there isnonpayment. It applies to any nonpayment, no matter howsmall, if you eventually want this to be part of your lien. Thismeans that you might have to give this notice several times,especially if there are small amounts unpaid during variousmonths. For example, if you have unpaid services for J uly,you must serve within 90 days of J uly 31.

How to Serve: Serve the owner and general contractor by Certified Mail, ReturnReceipt Requested.

Form andContent: The Notice must be in writing. State law pre-determines its

content and you must include certain mandatory language.Because of this, by far the best approach is to use a standardform so you do not leave out the required information. To havethis form prepared now online, see the list of forms at the end ofthis section.

Verified or

Notarized?: A verified notice simply means you sign it and are representingthe contents are true and accurate. A notarized notice is signed

in front of a Notary Public or other official. The notice need not beverified ornotarized.


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MECHANICS= LIENS

Who is Entitled

to a Lien: As to residential projects, a lien is only allowed by a generalcontractor, with limited exceptions. As to commercial andindustrial projects, a wide variety of persons who confer labor andmaterials on the project are entitled to a lien, including generalcontractors, subcontractors, laborers, and material/equipment

suppliers. But it also covers land surveyors, architects, andengineers, as well as persons who perform services in demolition;installing ornamental shrubbery and trees; and driveway/privateroadway work.

Fortunately, Tennessee allows subcontractors and suppliers ofany tier to entitled to a lien. This means, technically, a sub-sub-subcontractor would be entitled to a lien.

When to File/

Record: See Time Deadlines table. A general contractor is not requiredto record a mechanics lien to preserve lien rights. The generalcan simply wait for as much as 1 year after the last of the laborand materials have been supplied to bring suit to enforce a lien.However, this is not a good idea because the rights of third parties(selling the property to someone else or the recording of liens andencumbrances) could cut off ones rights before the filing of thatlawsuit. It is therefore recommended that the general recordbefore that lawsuit. That person has the option of either: (1)recording a Notice of Lien and Sworn Statement (the mechanicslien); or (2) recording a copy of the contract. Frankly, themechanics lien is the customary method, especially since thecontract documents could be many pages long and this wouldrequire more recording fees.

A subcontractor or supplier who has a contract with the generalcontractor or another sub records only a mechanics lien and nottheir contract. As described above, subs and suppliers can onlyfile their mechanics liens on a commercial project and notresidential.

Special rules if there is a Notice of Completion.Understandably, the new purchaser of a home wants to buy it freeof liens. On the other hand, general contractors and

subcontractors may not be paid at the end of the project and havea right to file a lien. The state of Tennessee as of J uly 1, 2008 hascome up with a compromise.

The owner or their representatives can record a Notice ofCompletion in the office of the county register of deeds. On the


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same day it is recorded, the owner must serve the generalcontractor, as well as subcontractors and suppliers who havepreviously timely served a Notice of Non-payment. The statute isvery clear on this point and uses the phrase filing and servingsimultaneously. This means recording the Notice and mailing itthe exact same day. If it is mailed the next day or later, there isnot compliance with the statute and technically generals and subs

get extra time. And there is no compliance if it is only recordedand not later mailed. But dont bet on it. To be safe, assume thissimultaneous requirement is complied with, unless it is absolutelyclear otherwise.

Watch out for gap periods. As stated below, assuming theNotice of Completion has been properly filed and served, asubcontractor on a commercial property has 90 days to record thelien from either: 1) completing your portion of the work or 2)completion of the overall project. But if you are performing workearly in the project, for example demolition, there can be a gap

between these two periods and if you file in that gap period, thelien will be invalid.

Example. As a demolition contractor, you finish your portion of thework on March 1. You have two time periods to file your lien. Thefirst period is 90 days from that date or May 31. The project is notcompleted until December 1. The secondary period is fromDecember 1 through March 1 of the next year. Your lien would beinvalid if you filed it in between J uly and November because it isinside the gap.

Premature Notice of Completion. If the Notice is filed before theactual completion date, it is as if the notice was never filed in thefirst place. Generals and subs have 90 days to record their lien.

Response to Notice of Completion. Section 66-11-143(e)(1)requires both the general and subcontractor to serve the owner awritten response after receiving a copy of the Notice ofCompletion. The response states the amount due as well as anaffirmation the amount does not cover charges incurred on otherjobs. There is some doubt as to whether the general contractormust serve this notice after the 2008 statutory changes, but areading of the section appears to continue this requirement.

The exception. If the general contractor has already recorded acopy of its contract or furnished the owner a sworn statement ofaccount, it is not required. But by definition, the sworn statementis sent when final payment is contemplated and so would not


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apply if you were filing a lien.

To simplify, here is an outline of the time limitations as of July 01,2008:

GENERAL CONTRACTORS

Residential. Notice of Completion simul taneously recordedand served. Lien and Generals Response to Notice ofCompletion within 10 days of filing the Notice of Completion.

Residential. Notice of Completion not simul taneouslyrecorded and served. Lien and Generals Response to Notice ofCompletion within 90 days of actual completion. If the Notice ofCompletion is not filed at all, the Generals Response would notbe required.

Commercial. Notice of Completion simul taneously recordedand served. Lien and Generals Response to Notice ofCompletion within 30 days of filing the Notice of Completion.

Commercial. Notice of Completion not simul taneouslyrecorded and served. Lien and Generals Response to Notice ofCompletion within 90 days of actual completion. If the Notice ofCompletion is not filed at all, the Generals Response would notbe required.

SUBCONTRACTORS

Residential. No mechanics lien allowed.

Commercial. Notice of Completion simul taneously recordedand served. Lien and Subs Response to Notice of Completionwithin 30 days of filing the Notice of Completion.

Commercial. Notice of Completion not simul taneouslyrecorded and served. Lien and Subs Response to Notice ofCompletion within 90 days of actual completion. If the Notice ofCompletion is not filed at all, the Subs Response would not berequired.

Where to

File/Record: Office of the Registrar of Deeds in the county where the propertyis located.


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Amount of

Lien: For unpaid labor, material, and equipment supplied.Previously, there was some authority that it also includedinterest and attorneys fees if part of the partys contract, aswell as consequential damages--for example, delay orimpact damages. Such examples would be overtime,extended overhead and other consequential losses.

Under the new law in 2007, this has changed. Now, the liencan only be for labor and materials that improves theproperty, and nothing else. So, there is now a specificexclusion under 66-11-102(e) for: interest, service fees, latefees, attorneys fees, and any consequential losses.

Also as of 2007, a lien can include unpaid extras. Thelegislature, however, did not state whether or not a changeorder must be in writing and signed before being so entitled.

The general rule is that materials will be part of the lien ifthey are incorporated into the improvement. However, italso applies to materials that are subject to normalwastage. An example, would be forming lumber used forfoundations and retaining walls. The cost for speciallyfabricated materials are also included, even if they are neverdelivered, as long as they cannot be readily re-used on otherprojects. Also included is building material that is not actuallyused in the improvement but is subject to diminution by thesalvage value of such material. Proof that materials weredelivered to the job site is prima facie evidence that theywere actually used.

The rental cost of tools, equipment, and machinery is alsoincluded but only at the reasonable rental value and notnecessarily the contract amount. This includes periods ofnon-use if this is provided for in the contract. It also includesthe full purchase price of such items if they have no valueto you after completing the job.

Lien claims are limited by the amount unpaid under thecontract with the general and cannot exceed that contractamount with authorized extras. The only exception is if thegeneral contractor serves a Notice to Owner early in theproject, liens may be asserted against the property even ifthe exceed the amount in the contract or what was paid tothe general contractor.


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There is also clarification as of 2007 as to what happenswhen you claim a lien which is later determined by the judgeto be willfully or grossly exaggerated in amount. In manystates, if this occurs, you lose your priority as between otherlien claimants and basically go to the bottom of the heapwhen it comes to collecting (you get paid only after everyoneelse is paid). In Tennessee, it is much more severe. If therehas been such a willful or gross exaggeration, the court has

the power to deny you recovery completely, and as of 2007,there is more teeth in the law: you can also be liable forexpenses and attorneys fees incurred by the person who isdefending the action.

As far as retention, Tennessee has one of the most liberallaws in favor of contractors. On large projects where yourcontract, either as a general contractor or subcontractor, is$500,000.00 or more, any retention must be placed into aninterest bearing, escrow account with a third party which issolely for your benefit. And, the retention cannot exceed five

(5) percent. You cannot get around this requirement byputting in a special provision in your contract. This reallygoes a long way to protecting contractors, but unfortunatelyit can be a bit of a hassle.

For example, assume you are a general contractor and havea 10% retention in all your subcontracts. It is a relativelyeasy method of to open up a separate business trustaccount of which you are signatory and where monies arekept separate from your general account. You certainlywould not want the subcontractors to be signatories on the

account because they could simply go in one day andwithdraw all the money. But Tennessee goes one stepfurther and requires that the account be with an escrowagent, which is definitely an overkill. You may wish to seekcompetent legal advice as to the particulars of setting upsuch an account.

The owner is required to release all retention to the primecontractor within 90 days after completion of the work. Inturn, the prime contractor then must pay retention to thesubcontractors within ten days of receiving that retention.

If the owner fails to deposit the retention for a generalcontractor into an escrow account, there is a whopping $300penalty for each day it is not deposited. It is a class Amisdemeanor if the owner does not deposit into escrow theretention within seven days of written demand by the generalcontractor.


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PropertySubject to

the Lien: A mechanic=s lien applies only to private projects. No lien isallowed in public projects against government property.If you are performing tenant improvement work, one of the

common questions is whether you can get a mechanics lienagainst the owners interest as well. Following the case lawin this state and others, the court will allow a lien on theowners property only if they find a tenant was the ownersagent and the owner had the right to control the conduct ofthe tenant. Some of the factors considered are whether thelease requires the tenant improvements, whether the cost ofthe improvement are paid for by the landlord, the extent towhich the owner controls the work, and whether the propertybeing improved ends up in the hands of the owner at the endof the lease. Because of the complexities in this area, youshould seek legal advice.

Furnishing

Information: Upon request, the general should furnish others withinformation about the owner so the required notices and liencan be filled out properly.

Under new law as of J uly 1, 2008, A lien claimant mayrely upon the information contained in the building permit asto the name and address of the owner and prime contractor,as well as the real property description. In other words, thisis a good source of information for prelien and mechanicsliens and no one can object if you use that information and itlater turns out to be erroneous.

Verified or

Notarized?: A verified notice simply means you sign it and arerepresenting the contents are true and accurate. Anotarized notice is signed in front of a Notary Public or otherofficial. A notarized and verified notice is required in thisstate.

Priorities: The rights of the lien claimants take effect as of the date onwhich actual visible work begins. But, Tennessee hasrecently amended its law so that the following shall not beconsidered visible commencement or the starting of priority:

(1) the placement of sewer or drainage lines or otherunderground utility lines or work preparatory thereto;


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(2) the putting up of temporary security fencing;

(3) the delivery of materials;

(4) demolition, surveying, excavating, clearing, filling, orgrading.

If the project is abandoned for 90 or more consecutive days,any lien for labor or material furnished after the project isresumed would start as of the date of visible operationsresumed.

The effect of this is that a construction lenderwho records a mortgage after the beginning of visible workwould be behind the contractors as far as priority. Asbetween the lien claimants themselves, everyone is equal,regardless of when they file, and if there are not enough

proceeds, they share pro-rata. The only exception is thatlaborers get their money first. The issue of priorities is acomplicated one and you should seek competent legaladvice.

Condos andSubdivisions:

Work performed at a condominium project gives you a lienon all the separate units. The lien is not applied to thecommon areas. The only exception is: 1) if work is donepursuant to a contract with a specific unit owner, the lienapplies only two that unit and, 2) if the contract with theassociation states the lien is to attach only to certain units,the lien would be proportional to them and based upon theamount of work done to each of them.

If you have a single contract covering separate units in asubdivision, you cannot place your entire lien on one lot orthe whole subdivision. You must apportion the contractbetween the individual lots, based upon the amount unpaidfor each specific lot. If this cannot be done, you could makea reasonable apportionment. But beware: the time starts

running on each separate building or unit and not thecompletion of the last unit in the subdivision.

Lien Release

Bond: The owner, or other interested person, may releasethe liens from the property by taking out a surety bond for anamount equal to the lien claim. Although the lien is removed


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from the property, the contractor must continue with the caseagainst the bonding company, and when that personprevails, can enforce its rights against the bond.

Once you have been paid or your lien has expired, make

sure you release it within 30 days of a written demand or youcan be liable for some stiff penalties: attorneys fees andcosts incurred by the owner.

The owner has the right to demand from the prime contractorthat he or she put up a surety bond to protect against anysubcontractor liens. But note, you do not have to enter into acontract with such a person making that demand. In otherwords, you can decide to pass on the project. But if you dothe project and the demand is made, you will have to go tothe time and expense of procuring such a bond.

Lien

Waivers: It is common for one to waive lien rights afterreceiving a progress draw. However, except as to laborers,you can also waive your lien rights if there is a specialprovision in your contract. Be very careful what you sign.

It is not uncommon for someone to receive apromissory note for unpaid services. This not considered awaiver of ones lien rights. On the other hand, the lienclaimant must go through all the same steps, includingprelien and mechanics lien notices, as if the promissory notewas never signed in the first place.

SwornAf fidavit to

Owner: There is a requirement upon general contractors toserve the owner with a special notice after completion of thejob and receipt of the money under the contract. Thegeneral must send the owner, by registered mail, adocument titled, Sworn Affidavit to Owner. It representsthat all persons on the project, including subs and suppliers,

have been or will be paid within 10 days. It also includes astatement that the general will hold the owner harmless fromany liens or lawsuits by subs and suppliers. This is verysevere and means the general must pay the ownersattorneys fees in defending a lien claim as well as anydamages imposed by the court.


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Diversion: If a contractor, subcontractor, or any other personintentionally uses money it has received for purposes otherthan paying for labor and materials it is contracted for, thatperson is guilty of a felony. For example, if the generalcontractor receives money from the owner but uses themoney for other projects or for personal purposes, a felony

will have been committed.

Self-Help Taking Back

Your Materials: If the project has been abandoned, or even if completed,materials have been delivered to the site, have not beenpaid for, and are unused, they can be taken back andrepossessed. Note that you cannot do so, especially if itcauses breach of the peace of material damage, removematerials that have already been installed.

LAWSUIT TO FORECLOSE LIEN

Introduction: Your lien is not valid forever. Because it directlyaffects the owner=s title, it has a limited shelf life and must beenforced within a short period of time. That enforcement isdone by filing a lawsuit to foreclose. J ust like the timedeadlines for a Pre-Lien or Mechanic=s Lien, the courtsstrictly construe these time limits which are called statutes oflimitation. Again, if you are literally one day late, the lien is

ineffectual.

When: The general contractor has 1 year to bring a lawsuit toforeclose after the work is finished or the materials aresupplied. Subcontractors and suppliers have 90 days fromthe date of filing their mechanics liens.

A word of caution. The general contractor or ownermay speed up the time in which you are required to bring thelawsuit by giving you written demand. If you receive it, you

are required to bring that lawsuit within 60 days after service,or you will lose your lien rights.

Arbi tration: Many construction contracts state that all disputes willbe decided by binding arbitration, as opposed to a courtproceeding by judge or jury. In fact, it has long been atradition to do so in the construction industry. Arbitration is


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usually quicker and less costly, especially because it cutsdown on expensive discovery. The decision is final andbinding, with no right to appeal. You lose your right for a jurytrial, but few contractors want that in the first place. Youusually pick an experienced construction attorney or retired

judge to hear the case in their conference room. It is just likea court proceeding with the same general rules of evidence,but more informal.

On the other hand, you can only foreclose your lien througha court proceeding, not arbitration. So, how do you keepyour arbitration rights and at the same time preserve yourlien rights? Simple. You bring a lawsuit to protect the lienand then immediately request the court to stay the courtproceedings. When arbitration is done, you go back to courtand turn the arbitration award into a judgment.

Need a Lawyer?In this country, every individual has the statutory right

to represent themselves. This means they can prepare allnecessary papers, appear at hearings, and actually try thecase. In so doing, the court considers you to be acting eitherin pro se or pro per. Before making this decision, considerthe following factors:

1. You are a professional and thoroughly know

the ins and outs of not only the construction industry but of theproject itself. The best lawyer on his or her best day willprobably not know more than 50% of what you know.

2. How is your public speaking abilities? If youare uncomfortable speaking to a group, you will even moreuncomfortable in court or arbitration. You could be thesharpest wit in town but may not be able to present yourarguments. Remember, appearing uncomfortable is perceivedas having deficiencies in your case. People usually think that ifyou are not comfortable about your own facts, then they mustnot be that strong.

3. If the other side has a lawyer, you might wantto think twice about representing yourself. You will certainlyknow the facts quite well, but you may be blindsided by legaltechnicalities.


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4. You may also want to think twice if this is areally nasty and emotional case. In other words, if the otherside is going for blood. Having a lawyer can shelter you fromthis emotional trauma. No matter how strong you are, lawsuitsare taxing not only on your time, but on your physical and

emotional energies.

5. If you have a good case in which you havecomplied with technicalities and performed good work, you areessentially engaging in a collection action. These actions aretypically very simple because there are few defenses ordefects alleged by the other side. It makes it easier for you torepresent yourself because it is more a question of when andhow much they will pay as opposed to whether you will win atall.

6. If you have a binding arbitration provision, youmay consider representing yourself. These proceedings aremuch more informal and the arbitrator tends to give you moreleeway. There are also fewer rules and not they are usuallynot quite as strict.

7. You could consider representing yourself butget advice along the way from a lawyer. It is much cheaperthat way. On the other hand, the lawyer cannot watch overevery move and you might slip up. Many times lawyers canalso help you with preparing the forms, simply putting your

name on the pleading. You can also bring in your lawyer at theend to actually try the case.

8. J udges and courts do not give legal advice.They only help you with what forms to use. However, clerkscan be invaluable in steering you in the right direction as far aswhere to file, time limitations, the nature of the form orpleading, etc. But, remember when it comes right down to theultimate advice, they cannot help you.

9. J udges usually treat you the same as anattorney which means they expect strict compliance with therules. Dont count on any judges give you slack.

10. The biggest dilemma is whether you shouldhire an attorney for a smaller case, typically in the $5,000 to$10,000 range. You have to watch this because you may eatup that amount in attorneys fees. You never make money onlawsuits, only lawyers do. Try to settle for the best price youcan get and move on.

Tennessee_Lien_Law_Summary.pdf

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