A dispute arose with a client during the process of installing a concrete patio. On the final day, progress was delayed by the client after the concrete had been poured and finished. The homeowner claimed defects and refused the final stage of detailing, cutting control joints, and cleanup. The next day the homeowner formally notified us via email claiming defects, refusal to pay the balance, and a threat we are in breach of the contract. This started the Right to Cure process. We performed an inspection and presented an offer to remedy which the claimant refused. Instead, the homeowner suggested the best thing to do is part ways and provide them a Lien Waiver. We agreed to the lien waiver under the condition that all parties sign a mutual release of all claims. We drafted the release and sent it to the homeowner for review. The release included standard paragraphs like covenant not to sue, confidentiality, etc. The client refused to sign the release with a confidentiality clause and indicated they would consider it if they were made whole and given back the project deposit. Multiple attempts were made by us to equalize the mutual release language suggesting to the homeowner please propose language they are comfortable with so a middle ground compromise can be reached. No response. During our attempts to compromise, we were getting close to the end of our lien rights window. Without a signed mutual release, and to not lose our lien rights, we served the homeowner with a notice of intent to lien. This expectingly did not go over well. The homeowner sent a loaded email filled with insults about the work performance, our business and employees' reputation, and that we are trying to silence them with a confidentiality clause. The client also stated we did not complete the job so do not have lien rights and if we file a lien they have no choice but to sue for slander of title. We anticipated the slander response being that it’s the common threat with lien filings. We believe we have lien rights. Our contract is very thorough defining what Substantial Completion is. The concrete project was completed enough that it can be utilized for its intended use. The homeowner delayed progress at the final stage, but the concrete can be used and is not a hazard. Overall, our intention is to still part ways and take the project's monetary loss. But the homeowner has been unpredictable so a mutual release of all claims is important. Are we at a true impasse? They’ll potentially sue us for slander of title if a lien is filed, and without a signed mutual release if they try to destroy our business reputation we are also protected by law from slander? Additionally, if our lien rights expire and they are still problematic, we could pursue breach of contract? Any input you have is appreciated!