"If he files an action to foreclose before you file suit, you can simply respond with counterclaims and raise your defenses in the action to foreclose on the lien." Excellent response to my concerns. Also appreciate references to 93A and MGL c. 142A . It was important for me to understand : "Those a...ren't mutually exclusive, sometimes a breach of contract can also be a 93A action" Thank you so much. I am a former teacher and appreciate this opportunity to be educated on the critical questions.