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Which date is last furnishing date

PennsylvaniaLien Deadlines

Hello! We are uPVC windows and doors supplier, and we are working in 20 states all over USA. We are delivering windows under main agreement with client within few months, and if client need something additional we sign additional agreement (or client change order) and we are delivering additional orders paid by client until project is completed. My question is regarding last delivery date, which date should be our last delivery date for Lien purposes, when we delivered main order last container or we can extend this to when we delivered last additional order paid by client? If this depends from state to state, could we get somewhere a list with states specified? Thank you!

9 replies

Nov 29, 2021
Every state has different requirements for the “last date” that work is performed and/or materials are delivered. Some states also require notices of commencement of performance and/or notices of completion of work. In Pennsylvania, the “last date” is generally the last date that materials (base contract or change order) are delivered to the Project site. However, this interpretation can differ depending on how your materials are delivered or how the work is performed. It is best to talk through in detail issues associated with mechanics’ liens with your attorney because the interpretation of mechanics’ lien rights is both legally and factually specific.
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Nov 30, 2021
In Pennsylvania, the last date when you delivered material of any kind to the product site will be the triggering date for your lien deadline. Other states may differ. As far as a state-by-state list, their are several legal publications that have compiled lists for the lien requirements by state. You may be able to access those on-line. Otherwise, you'll have to go through a legal research provider/site like Lexis or Westlaw to access them.
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Dec 2, 2021

Thank you for your answers.

But in PA I read that Punch list items do not extend Lien deadline, is that true?

Our clients sometimes hold final payment until punch list is completed, so our payments are delayed and we are still delivering materials.

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Dec 2, 2021
You are correct if the "punchlist work" is work that is required to correct deficiencies in your work or product. However, if the "punchlist work" is a required work item or material that was not previously completed or supplied (that is necessary to complete the work), an argument can be made that the delivery or completion of that punchlist item is the last item of work/material and that the lien must be filed within 6 months of the date that this final item is completed/furnished.
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Dec 14, 2021

Thank you for answers.

 I will add few more as we already filed the Lien.

1. In our purchase agreement we have owner listed, but Levelset added one more company as owner. Is that okay if we listed two owners on the Lien?

2. Which date on the Lien should be under "Date from which interest on the amount of claim is claimed" - I added our last delivery date here, is that corret?

Thank you

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Dec 14, 2021
Yes ... you can name as many owners as you want as long as they have some ownership interest in the Property. The last date when you delivered materials is correct.
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Dec 21, 2021

Hello,

Actually, our last delivery date was 10/07/2021, and client owes us for this delivery $1,550.59, for delivery from 09/27/2021 - $445.37 and our main not paid invoice from delivery made on 05/20/2021 - $53,050.20. We calculated 150 days from last delivery on 10/07/2021 and it is 05/10/2021 - our last day covered. We submitted Lien, and to the date "Date from which interest on the amount of claim is claimed" I added 05/20/2021 - our main not paid delivery date. Could you please check is this is correct, just want to make sure our Lien is filed correctly.

Thank you very much

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Dec 21, 2021
The 150-day deadline is technically correct. However that it not the deadline for the Mechanics' Lien claim itself. The deadline for the line is 6 months from the date when you last supplied materials. The 150-day deadline comes into play because you are a material supplier. A material supplier is considered to be a subcontractor under the Pennsylvania Mechanics' Lien statute. A subcontractor is required to serve a Notice of Intent to File Mechanics' Lien Claim on the owner and at least 30-days before it can file its mechanics lien claim. That Notice is condition precedent to a subcontractor's right to file a mechanics' lien. Also, please keep in mind that if Notice of Commencement was filed by the Owner or its agent on the Pennsylvania Construction Notices Directory, a subcontractor or supplier must file a Notice of Furnishing with the Directory within 45-days of providing labors or materials at the job site. As with the Notice to Intent to File a Mechanics' Lien claim, the filing of a Notice of Furnishing is condition precedent to the right to file a mechanics lien if a Notice of Commencement has been filed/posted by the Owner. A failure to do so will result in the forfeiture of the right to file a mechanics lien.
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Dec 22, 2021

Steven, 

Thank you very much for your insights on this, looks like VA Lien law is complicated.

Preliminary notice 43-11 was sent 09/30/2021 to client and owner.

Notice of intent to Lien was sent 10/5/2021 to client, Levelset do not show that we should send this to owner, or that Notice of intent to Lien is required. Are you saying it is otherwise?

Post Work 43-11 Notice to owner was completed in Levelset 11/19/2021 ( if last delivery was 10/07/2021, we sent 43 days after last delivery, because we thought we will deliver one more order but we put it on hold becouse of non payment). Levelset shows this document as required and 30 days deadline to do this. Do you know if this notice is recorded somewhere within a state? 

Lien deadline in levelset is 90 days from last delivery, so we filed Lien on 12/02/2021 when our last delivery was 10/07/2021, so we submitted 56 days after last delivery.

Looks like Notice of Commencement was not filed - I checked here by project name https://www.pa.gov/dgs/state-construction-notices-directory/search. 

Thank you a lot!

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