That indicates that they will defend the mark and you will have a fight on your hands at TTAB.

Without anything in writing, there is no good way to contest on your side and defend on his side. 

Get a CPA who knows this stuff in and out who can help set it up and defend when the IRS comes calling.

When the former owner became aware of the forgery he filed suit to set the sale aside naming my insured as a defendant. 

Further, should foreclosure, deed in lieu, etc occur, there is no need to form another entity to hold title, the same series can hold title with the same asset protection benefits.While I’m on my asset protection soapbox I will share that many investors make the mistake of either going in for very expensive, dubious value asset protection strategies (foreign asset protection trust based in Nevis and held in a Lichtenstein Corporation while being based in Bahamas and managed by a trustee related to the former Bahamian Prime Ministers wife’s third cousin) or don’t want the hassle so have no asset protection at all.  

The defendant's name in the claim, who had the dogs during the incident is not even on the lease agreement.

If you have lined up a passive investor to contribute all or most of the needed capital you may be able to get by with just an operating agreement and have the investor have a somewhat more active role in the operation so you don’t get trapped later, if things go bad, into having to defend a securities registration lawsuit.  

Once as a plaintiff (I won) and once as a defendant in an escrow dispute (I won that one too). 

If the guy is in or near foreclosure, I wouldn't want to have to defend what the definition of a foreclosure consultant is, or whether or not I made the borrower feel like I was presenting myself or my offer as one requiring registration as a foreclosure consultant.

The Final Judgement also states the following:"On filing the certificate of sale, defendant(s) and all persons claiming under or against defendant(s) since the filing of the notice of lis pendens shall be foreclosed of all estate or claim in the property, except as to claims or rights under chapter 718 or chapter 720, Florida Statues, if any."