Johnny, I’m sorry to hear about your plight. Those lawsuits are unfortunately common against park owners. Litigation targets those who are perceived to have resources (you, park owners), and avoids that aren’t thought to have resources (tenants with dogs). Park owners have been sued and lost for claims arising from tenant owned, and even stray dog bites. One of our worst losses ever involved a stray dog.
Your chances of success depend on the facts of the matter (any prior notice of that dog being an issue?), your state, and your particular legal jurisdiction and judge. We’ve paid policy limits for dog bite lawsuits and we’ve beat them and paid nothing - including a TN case recently where we got out on Summary Judgment. That’s rare, but it gave me a big smile.
My advice is to seek legal counsel/defense - at least a first meeting. You’ll be asked to pay a legal retainer (up front payment of $10k or so) for the attorney to get involved representing you in a court case. Be careful contacting the plaintiff’s lawyer directly. Anything you say or write to him/her can be used against you in court. A short cut would be to hire a lawyer to send a letter advising the plaintiff’s lawyer you have no insurance and limited resources in hopes this spurs a quick settlement of $5k or $10k.
The good news - no notable bodily injury. Woohoo. That limits their ability to get a large judgment against you. These cases often settle for 3x total medical bills. If there are few of those, that’s good for you.
Don’t let the plaintiff know you are selling the park, else they will leverage that to demand more. Pending litigation usually kills or postpones property sales. You may be able to contract with the buyer that you’ll defend and indemnify him/her from litigation relating to pre-sale events, but that promise is limited by your financial ability to do so.
Good luck. Call me on my cell if you’d like to visit 281-460-8384. Kurt