File the lis pendens with the circuit court. Talkov Law's real estate litigators provide a free checklist of requirements to file a lis pendens (notice of pending action).Take Away: For decades, purchases at foreclosure sales have served their Notice to Quit after recording the Trustees Deed Upon Sale. 1. You must first file a lawsuit in which title to the property is at issue between the parties; 2. A Notice of Action, also known as Lis Pendens (Latin for "a suit pending"), may be recorded in a lawsuit that involves title to real property. Lis pendens is a notice lenders use when they initiate a foreclosure sale. : When a property owner is facing foreclosure, they may file a lis pendens to contest the foreclosure or seek other remedies through litigation. The form lis pendens below provides an example of a notice of pending action sent for recording with the county recorder. This document and to investigate each property bidders are interested in purchasing before bidding at the tax sale. A Lis Pendens is filed with the County Recorder in the county where the piece of property that the law suit involves is located.