There are many strategies for off market...Searching public records for preforeclosure defendants, evictions (plaintiff may be tired landlord), etc can be a good source.Driving for deals is time intensive, but tried-and-true.

They will defend the claim and know the legal levers to pull in situations like this...I recently did the same for an auto claim that we clearly aren't liable for, but the other driver's insurance disagrees.

Effectively though, since nothing has been approved by the IRS, you'll need to be sure the position you're taking is conservative enough to be able to successfully defend if challenged.

Not to mention, in the event a lawsuit is brought, the plantiffs attorney will name the deed holder LLC as a defendant and likely the management company as well. 

What are the impacts of a citation on my rental property and can I defend it in court?

pg 10"From the Fund’s inception in or around February 2018, the Defendants, both individually and through project managers at NRIA, represented to investors and prospective investors that NRIA was a solvent, profitable business that generated significant cash flow, separate and apart from investor fundraising.

While agent would prefer to defend status quo but the ball would be on brokerage and the new brokerage that has more efficient transaction system and able to offer something radically simpler for buyer and seller.

In Canada the prime minister made some announcement about trying to get a federal lease that all the provinces need to use as well as posting the previous rent so tenants can negotiate the rent prices. 

But then one of the defendants answered the summons, the day before court. 

What I'm looking for is a decision where despite the plaintiff's demand for the defendant to convey the real property, the court decided that a damage award would be sufficient.