A prime contractor, on a time and materials contract with a cap, failed to finish the job and performed substandard work. The homeowner met with the contractor disputed that monies were owed given the poor workmanship and that the contractor exceeded the cap in the time and materials contract but did not finish the job. The contractor presented the homeowner with a bill and walked off the job and removed his tools from the job site . Some 70 days after walking off the job, the contractor mailed to the homeowner a mechanic's lien and recorded the lien 91 days after the dispute. Next he filed a lawsuit in court to enforce the lien 62 days after recording the lien. The courts, because of covid, did not issue a case number or summons as they are 9 weeks behind in processing filings. Meanwhile, the contractor through his attorney filed for arbitration and attached the complaint to enforce the mechanic's lien. Questions: 1. Did the contractor have grounds to file a mechanic's lien? 1. Did the contractor meet the time requirements for filing a mechanic's lien? 2. Can he demand the matter be heard through arbitration even though the courts have not issued a summons or case number and the homeowner has not been formally served (only provided with the complaint through arbitration) and cannot file an answer in court regarding the mechanic's lien that is clouding the homeowner's title because no case number has been assigned but the arbitration association placed the matter on a fast track? 3. Can the homeowner make a claim for damages for clouding title?