In February 2019, I got a call from a potential customer he had water damaged from a storm. We provided Emergency service to mitigate the damages it turned into an insurance claim. There was damage to the master bedroom upstairs and the family room below it. Months went by while negotiating on a scope of work with the insurance company. As this house was a horder house, and the flooring continued through the home, we needed to pack out 4000sf home. Pack out was started on 7/1/2019 and completed on 7/22/2019. While the house was empty, the customer added to the scope and requested a full kitchen remodel and both upstairs bathrooms and upgraded flooring, adding over $90,000 change order. The construction started on 7/29/2019. During construction, the customer had hired a contractor to install a water softener in his garage witch ended with another flood. The other contractor filed a claim with his liability insurance and had a mitigation contractor to mitigate the damages. When it came to rebuilding the garage, he wanted us to do it. The insurance adjuster agreed and had us pack out the garage and document for any damaged items. The garage was also full of contents to the ceiling. We completed the original scope except for a small punch list. Around this time, Covid-19 was starting, and the customer did not want us in his home but it was okay for us to pack out his garage. On 2/26/2020, we started the garage pack out and completed the packout on 3/9/2020. We stored his contents at a storage unit locally. During the garage, repairs were completed and brought back. After the pack out was completed, he did not want us on his property at all and asked us to wait until further notice. by this time; he owed me approximate $15,000 for the original packout of the main house, $10,000 from the change order, and $10,000 for the garage packout. When i tried to collect money he owed, he said the insurance had not released any funds, and he did not want to pay me the $10,000 from the change order. Because that is all the cash in hand that he owed not from insurance, and that was his leverage for us to come back and finish. Yet he was the one holding the project up. on 5/18/2020 i submitted an intent to lien. he then called us and asked if he needed to hire a lawyer. he claimed on an email that I had not finished his project, that is why he would not pay us. I reminded him that he did not let us complete the garage repairs. we agreed to complete the repairs and punch list. the garage repairs were completed and packed. All the contents put back on 8/6/2020. On the last day of the garage repairs, he was not home as he is a firefighter and was deployed. His wife was home, and she said she would create a list of all the items that need touch-ups. To this day, he now owes us approx $40,000 and has not responded to us. 8/6/2020 was the last day worked. can i file a lien?