Itemization of Mechanic’s Lien Not Necessary Where Construction Contract Apprised Owner of Lienor’s Claim

New York Lien Law § 38 states that the holder of a mechanic’s lien “shall, on demand in writing, deliver to the owner or contractor making such demand a statement in writing which shall set forth the items of labor and/or material and the value thereof which make up the amount for which he [or she] claims a lien, and which shall also set forth the terms of the contract under which such items were furnished.” In Associated Building Services Inc. v Pentecostal Faith Church, 112 A.D.3d 1130, 976 N.Y.S.2d 699 (3rd Dept. 2013), the Court held that a lienor is not always required to provide an itemization of labor and materials furnished to substantiate its mechanic’s lien.

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