Fill out the form to access a sample of Practical Guidance. A lis pendens must be recorded with respect to lawsuits that seek to foreclose construction or preconstruction services liens.Fill in the blank form formatted to comply with all recording and content requirements. Response 3: You can file lawsuit for wrongful foreclosure and ask the Court to reverse the sale. A lis pendens is a common tool used in Florida to put third parties on notice of a pending lawsuit against real estate.