Cenlar’s Harris Cases are Confusing. But We’re More Confused by Marc Dann’s Legal Picks in Texas

Erin Shank may have 40 years legal experience but she’s only been joint counsel on one other, ongoing foreclosure case.

LIT Commentary

After a brief conversation with Marc Dann on Twitter about another Texas foreclosure defense case, 24 hrs later, this Cenlar case would “provisionally settle”.

LIT was tracking the case, but had not created a published foreclosure tracker for this particular lawsuit, as we have another ‘Harris v Cenlar FSB‘ case we were watchin’.

However, when the settlement notice was filed in this case on Friday, 15 July, we noted that Marc Dann was pro hac vice in this case too.

Further, we observed the Texas (local) counsel attached to the defense team was a lady by the name of Erin Shank, someone we haven’t seen in a foreclosure defense filing in the past.

So we performed a quick audit, and the results fit the current legal ochlocracy and corruption we’ve been highlighting on our main website at Laws In Texas and also our microsites, like Cenliar.com.

First, Erin Shank provides debt management services on her website, but she’s not registered with the Texas OCCC. That violates Texas law.

Second, Erin Shank may have 40 years legal experience but she’s only been joint counsel on one other, ongoing foreclosure case.

Third, and we’ll need to look at this later, but we’re feeling a bit uncomfortable with Dann Law hooking up with local counsel, as there’s a lot of ethics and State Bar requirements surrounding ‘referrals’ and sharing fees etc, but that’s something we’re just sayin’ MAY be an issue, but would need a separate investigation.

Harris v. Cenlar, FSB


District Court, W.D. Texas

MAR 24, 2020 | REPUBLISHED BY LIT: APR 19, 2022

Marc Dann is Pro hac vice in this case too, LIT just discovered, from the notice of settlement filed today, 15 July, 2022.

U.S. District Court [LIVE]
Western District of Texas (Waco)

Harris v. Cenlar, FSB
Assigned to: Judge Alan D Albright
Referred to: Judge Derek T. Gilliland
Cause: 12:2605 Real Estate Settlement Procedures Act (RESPA)
Date Filed: 04/06/2020
Jury Demand: Plaintiff
Nature of Suit: 890 Other Statutory Actions
Jurisdiction: Federal Question
Acquanlan Deonshay Harrisrepresented byErin B. Shank
Law Office of Erin B. Shank, P.C.
1902 Austin Avenue
Waco, TX 76701
(254) 296-1161
Fax: 254/296-1165
Email: shankcourtnoticesonly@gmail.com
Dann Law
Dann Law
15000 Madison Avenue
Lakewood, OH 44115
Fax: 216-373-0536
Email: mdann@dannlaw.com
Cenlar, FSBrepresented bySabrina A. Neff
Husch Blackwell LLP
600 Travis St., Suite 2350
Houston, TX 77002
Fax: 713-647-6884
Email: sabrina.neff@huschblackwell.com


Date Filed#Docket Text
03/24/20204STANDING ORDER from U.S. District Judge Alan D. Albright regarding scheduled civil hearings. Signed by Judge Alan D Albright. (Attachments: # 1 Amended Order from Chief Judge Garcia re COVID19, # 2 Order from Chief Judge Garcia re COVID19)(mc5) (Entered: 04/06/2020)
04/06/20201COMPLAINT (Filing fee $ 400. Receipt #0542-13427654), filed by Acquanlan Deonshay Harris. (Attachments: # 1 Exhibit 1-Letter Noticing Bankruptcy Filing, # 2 Exhibit 2-Notice of Servicing Transfer, # 3 Exhibit 3-Application, # 4 Exhibit 4-Letter Quit Claim, # 5 Exhibit 5-Letter, # 6 Exhibit 6-Letter with Quit Claim Deed, # 7 Exhibit 7-Cenlar Letter, # 8 Exhibit 8-Resubmitted Application, # 9 Exhibit 9-Denial Letter, # 10 Exhibit NOE 1, # 11 Exhibit 11-Application (Correct), # 12 Exhibit 12-Application Acknowledgement, # 13 Exhibit 13-NOE Confirmation of Delivery, # 14 Exhibit 14-FC Inspection Letter, # 15 Exhibit 15-NOE Acknowledgement, # 16 Exhibit 16-NOE 2, # 17 Exhibit 17-Cenlar Letter, # 18 Exhibit 18-Response, # 19 Exhibit 19-NOE 3, # 20 Exhibit 20-Response, # 21 Civil Cover Sheet)(Shank, Erin) (Entered: 04/06/2020)
04/06/20202REQUEST FOR ISSUANCE OF SUMMONS by Acquanlan Deonshay Harris. (Shank, Erin) (Entered: 04/06/2020)
04/06/20203Summons Issued as to Cenlar, FSB. (bw) (Entered: 04/06/2020)
04/13/20205MOTION to Appear Pro Hac Vice by Erin B. Shank /Motion for admission Pro Hac Vice for Marc E. Dann ( Filing fee $ 100 receipt number 0542-13450599) by on behalf of Acquanlan Deonshay Harris.. Motions referred to Judge Jeffrey C. Manske. (Shank, Erin) (Entered: 04/13/2020)
04/14/20206ORDER GRANTING 5 Motion to Appear Pro Hac Vice by Marc E. Dann. Pursuant to our Administrative Policies and Procedures for Electronic Filing, the attorney hereby granted to practice pro hac vice in this case must register for electronic filing with our court within 10 days of this order. Signed by Judge Jeffrey C. Manske. (lad) (Entered: 04/14/2020)
05/28/20207WAIVER OF SERVICE Returned Executed by Acquanlan Deonshay Harris as to Cenlar, FSB. Waiver sent on 5/21/2020, answer due 7/20/2020. (Shank, Erin) (Entered: 05/28/2020)
07/20/20208Defendant’s ANSWER to 1 Complaint,,, and Affirmative Defenses to Plaintiff’s Original Complaint by Cenlar, FSB.(Neff, Sabrina) (Entered: 07/20/2020)
07/21/20209DOCKET CONTROL ORDER PURSUANT TO RULES 16(b) AND 26(f). Signed by Judge Jeffrey C. Manske. (lad) (Entered: 07/21/2020)
08/10/202010Certificate of Interested Parties by Cenlar, FSB. (Neff, Sabrina) (Entered: 08/10/2020)
08/10/202011Rule 26(f) Discovery Report/Case Management Plan by Cenlar, FSB. (Neff, Sabrina) (Entered: 08/10/2020)
08/10/202012Proposed Pretrial Order /Scheduling Order by Acquanlan Deonshay Harris. (Dann, Marc) (Entered: 08/10/2020)
08/20/202013SCHEDULING ORDER: Motions due by 6/1/2021. Consent to Trial by Magistrate due by 8/24/2020. Amended Pleadings and Joinder of Parties due by 9/17/2020. Pretrial Conference set for 9/2/2021 10:30 AM before Judge Alan D Albright. Jury Selection and Jury Trial set for 9/13/2021 09:00 AM before Judge Alan D Albright. Signed by Judge Jeffrey C. Manske. (am) (Entered: 08/20/2020)
08/24/202014NON-CONSENT to Trial by US Magistrate Judge by Acquanlan Deonshay Harris. (Dann, Marc) (Entered: 08/24/2020)
05/27/202115Joint MOTION to Extend Scheduling Order Deadlines with Amended Scheduling Order by Acquanlan Deonshay Harris. (Attachments: # 1 Proposed Order). Motions referred to Judge Jeffrey C. Manske. (Shank, Erin) (Entered: 05/27/2021)
06/01/202116AMENDED SCHEDULING ORDER re 15 Joint MOTION to Extend Scheduling Order Deadlines with Amended Scheduling Order filed by Acquanlan Deonshay Harris, ( Discovery due by 8/15/2021,, Dispositive Motions due by 12/30/2021,, Jury Selection & Trial set for 3/21/2022 09:00 AM before Judge Alan D Albright,, Pretrial Conference set for 2/10/2022 01:30 PM before Judge Alan D Albright,). Signed by Judge Alan D Albright. (wg) (Entered: 06/01/2021)
06/01/202117ORDER GRANTING 15 Motion to Extend Scheduling Order Deadlines. Deadlines reset; Final Pretrial Conference reset for 2/10/2022 01:30 PM before Judge Alan D Albright; Jury Trial set for 3/21/2022 AM before Judge Alan D Albright. Signed by Judge Alan D Albright. (klw) (Entered: 06/01/2021)
07/08/202118Notice of Alternative Dispute Resolution/Mediation Outcome: Did not Settle. Amount of fee: $1,300. (Pattillo, Rowland) (Entered: 07/08/2021)
01/31/202219MOTION to Continue Deadlines of Amended Scheduling Order [Doc 17] by Acquanlan Deonshay Harris.. Motions referred to Judge Jeffrey C. Manske. (Dann, Marc) (Entered: 01/31/2022)
01/31/202220SUPPLEMENT to 19 MOTION to Continue Deadlines of Amended Scheduling Order [Doc 17] by Acquanlan Deonshay Harris. (Dann, Marc) (Entered: 01/31/2022)
02/08/202221NOTICE of Filing Corrected Order Granting Unopposed Motion to Extend Final Pretrial Conference and Jury Trial Dates by Acquanlan Deonshay Harris (Dann, Marc) (Entered: 02/08/2022)
02/08/202222ORDER GRANTING 19 Motion to Continue Pretrial Conference set for 5/20/2022 before Judge Alan D Albright,Jury Selection set for 5/31/2022 M before Judge Jeffrey C. Manske, Jury Trial set for 5/31/2022 before Judge Alan D Albright, Signed by Judge Alan D Albright. (sv) (Entered: 02/09/2022)
04/06/202223ORDER REFERRING CASE to Magistrate Judge Derek T. Gilliland. Signed by Judge Alan D Albright. Case No Longer Referred To Magistrate Judge Jeffrey C. Manske. (bot1) (Entered: 04/13/2022)
05/03/202224Joint MOTION to Extend Scheduling Order Deadlines of Amended Scheduling Order (Doc.17) by Acquanlan Deonshay Harris. (Attachments: # 1 Proposed Order Granting Joint Motion for Extension of Deadlines of Amended Scheduling Order (Doc 17)). Motions referred to Judge Derek T. Gilliland. (Dann, Marc) (Entered: 05/03/2022)
05/06/202225ORDER GRANTING 24 Motion to Extend Scheduling Order Deadlines Pretrial Conference set for 7/18/2022 before Judge Alan D Albright, Jury Selection set for 8/1/2022 before Judge Jeffrey C. Manske, Jury Trial set for 8/1/2022 before Judge Alan D Albright Signed by Judge Alan D Albright. (sv) (Entered: 05/06/2022)
07/15/202226NOTICE of Settlement by Cenlar, FSB (Neff, Sabrina) (Entered: 07/15/2022)



PACER Service Center
Transaction Receipt
07/15/2022 15:41:59

Who is Texas Lawyer Erin Shank?

I am a lawyer, a mother, a wife, a retired teacher, and an owner of two small businesses here in Central Texas. I have been a Texas bankruptcy attorney for nearly 40 years and have tirelessly advocated for more than 6,000 Central Texans during some of the most difficult times in their lives.

I know how to listen to folks, understand their issues, and then fight for them in Court. For nearly 4 decades, I have been an advocate for Texans across Waco and McLennan County, and I’m ready to continue to fight for them in Austin. ​

Our current representative has been in office for over 18 years. After a deadly winter storm and two years of a pandemic, we can’t afford to wait for a representative who will advocate for Waco and McLennan County.

We deserve better. Erin Shank is running for Texas House District 56. With four decades of experience representing Waco and McLennan County, she’s ready to fight for her community.

Tax Debt Resolution Lawyer in Killeen & Waco

Serving Clients Throughout Central Texas

If you are dealing with tax debt, you may be upset and confused about the best way to move forward. Tax laws are complicated, and it is easy to feel anxious and overwhelmed. Now is the time to discuss your options with an experienced tax debt resolution lawyer.

Attorney Erin B. Shank has 40 years of experience helping people with tax debt relief. Erin has a deep knowledge of state and federal tax laws. She has helped thousands of Texans address their overwhelming tax debt.

When it is time to deal with your tax debt, let Erin B. Shank give you a helping hand.

Erin is committed to your safety and convenience. She offers a 100% contact-free practice. Erin uses technologies such as Zoom, electronic document gathering, e-filing, and digital signatures to represent her clients. She can help you resolve your debt from the comfort, safety, and convenience of your own home.

Do not wait another day to begin resolving your back taxes. Contact Erin B. Shank today. For a free consultation, contact Erin online or call (254) 690-4110.

How a Tax Debt Resolution Lawyer in Central Texas Can Help

Tax law is complex, and your options will depend on your unique facts and circumstances.

When you need tax debt help, a lawyer can assist you by:

  •  Analyzing your case to understand your debts and your income
  • Advising you on the law and your options for IRS tax debt help
  • Guiding you on options such as bankruptcy
  • Being your advocate and representing you get bankruptcy relief from tax debt.

If you are facing a mountain of debt and need tax relief services, Attorney Erin B. Shank is ready to help.

Common Tax Debt Resolution Strategies

Every tax debt case has unique circumstances.

Many cases rely on these tax debt resolution strategies:

  • Chapter 7 bankruptcy: A lot of people think that taxes are not dischargeable in bankruptcy cases, but that is not true. If you owe federal income tax and the tax return was due more than three years ago, was filed more than two years ago, and was assessed by the IRS more than 280 days ago, that tax debt is dischargeable in a Chapter 7 bankruptcy case.
  • Installment agreement: In some cases, it may make sense to create a plan and pay off your tax debt by multiple payments over time. This option may allow you to reduce the monthly financial pressure that you face.
  • Currently non-collectible status: If you are facing a tax debt that may cause you significant hardship, you may qualify for currently non-collectible status. Under non-collectible status, the IRS will cease collecting from you, and you do not have to make payments. After ten years, this debt is no longer collected by the IRS. While you are in non-collectible status, all IRS garnishments and other collection techniques stop. The non-collectible status will not eliminate your debt, but tax debt that is more than ten years old is no longer collected by the IRS.
  • Offer in compromise: depending upon the facts of your case, you may be able to present an offer in compromise on your IRS back taxes. an offer in compromise allows you to settle your IRS tax debt for less than you owe. This offer, which is based on your income, assets, and expenses, requires detailed documentation. If you are facing a tax debt that could cause significant hardship, this may be an option for you to consider. However, this option is very difficult to obtain from the IRS and is therefore rarely used by Erin.
  • Chapter 20: Erin has filed a Chapter 7 bankruptcy case to discharge all debt except for non-dischargeable IRS debt. After the client is discharged in their Chapter 7 case, she files a Chapter 13, and the only creditor paid in that case is the IRS debt that was not discharged in the prior Chapter 7 case. This is frequently called a “Chapter 20” bankruptcy case (7 + 13 = 20). Clients can pay their Chapter 20 case off early and reduce the taxes and penalties that are frequently very high in non-bankruptcy repayment plans.

When Do I Need to Seek Tax Debt Resolution?

Tax debt is a serious problem, but IRS tax debt help is available.

Turn to Attorney Erin B. Shank for help if you are facing any of the following problems:

  • You owe the IRS a significant amount of money.
  • The IRS is trying to collect the debt.
  • The IRS is garnishing you.
  • You are facing financial hardship because of your debt.

Don’t Take on the IRS Alone

The IRS is a powerful organization whose trained staff and attorneys focus on debt collection. Those attorneys may have their eyes on you. Now is the time to let attorney Erin B. Shank find the best way to resolve your debt.

As an experienced tax debt resolution lawyer, Erin can handle any negotiations with the IRS. Erin can ensure that all paperwork is correctly completed and filed on time. She can advise you on options such as bankruptcy that make the most sense in your situation.

Erin also has a close  professional relationship with a local Certified Public Accountant who helps her represent her clients. Many clients have delinquent returns that need to be filed or amended, and working with this accountant enables Erin=s clients to have the benefit of both a tax resolution lawyer and accountant address their tax resolution needs.

Find Out How a Tax Debt Resolution Lawyer Can Help

IRS officials specialize in collecting money, and they will do everything in their power to get it. If you are facing tax debt, it is important that you talk as soon as possible with Erin B. Shank.

She has 40 years of experience providing back tax help to people just like you. Erin and her paralegals are committed to helping you find the IRS debt relief you need. Erin=s law office puts your safety and convenience first, with a 100% contact-free practice. She can help you resolve your debt from the safety of your own home.

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Erin Shank, who taught in the Baylor Law School for over 10 years and owns a bankruptcy law firm in Waco, announced her candidacy for the District 56 House seat in the Texas House of Representatives on Tuesday.

District 56 includes McLennan County, housing 176,727 people. Shank will run against incumbent Charles “Doc” Anderson, who has served as the representative since 2004.

Shank said the statewide freeze that caused the state electrical grid to fail largely led to her decision to run for election.

“I have always been interested in politics — I have two degrees in political science and journalism and a law degree, so I’m very involved in politics, especially at the local level — but it was the ice storm that killed two of my clients,” Shank said. “They were warned 10 years ago that the grid would fail and be a catastrophic failure and you need to winterize it, and they didn’t, and that’s where I said, ‘We deserve better.’”

Shank has been practicing bankruptcy law for 40 years in Texas. Her firm, Central Texas Bankruptcy, now follows a “touch-free” method in response to the global pandemic, according to its website.

Shank will run as a Democratic candidate while Anderson will run as a Republican candidate in the 2021 race.

“I want to go down there and not force a very left agenda, but just come right in the middle and get to some common sense stuff if we think about this stuff together,” Shank said.

Shank said she will begin her campaign with a listening tour during the holidays — when she will travel across the county listening to individuals’ concerns — and will then begin her field tour in January.

“I am a Democrat, but I am not weighted to the party,” Shank said. “If something is better for McLennan County this way than that way, I am going to vote for what’s best for McLennan County.”

Additionally, Shank graduated from The University of Texas at Austin LBJ Women’s Campaign School on Nov. 13 and launched her campaign on Nov. 15.

“I would encourage many more women to do this because I think we need women in politics, especially moms,” Shank said. “There’s so many issues that affect families and children, and I’m doing this for this next generation. We need to live in a better place.”

Shreveport, La., junior Veronica Bonifacio Penales serves on Shank’s campaign staff and is a student activist. Penales said she believes voters must begin to think of the direction they want representatives to take.

“Doc Anderson has served for the last 14 years as Texas District 56 representative, yet everything he has successfully completed out of his last seven campaigns worth of promises could easily amount to only one term’s work — and that’s stretching it,” Penales said. “The question voters need to ask themselves: Are steps forward really steps in the right direction when the path is so obviously a circle?”

Shank said she wants young people to know how important this election is and to look at it with an open mind.

“Let’s stop this propensity that university kids have of being classified as non-voters,” Shank said. “I would urge voters to look — not just pull a party lever — but put the lever for the most qualified candidate.”

U.S. District Court
Northern District of Texas (Fort Worth)
CIVIL DOCKET FOR CASE #: 4:22-cv-00308-O

Create an Alert for This Case on RECAP

Harris v. Cenlar FSB et al
Assigned to: Judge Reed C. O’Connor

Case in other court: 96th Judicial District Court of Tarrant County, 096-332846-22

Cause: 28:1332 Diversity-Breach of Contract

Date Filed: 04/13/2022
Jury Demand: None
Nature of Suit: 190 Contract: Other Contract
Jurisdiction: Diversity
Rodney D. Harrisrepresented byD Kimberli Wallace
D Kimberli Wallace PLLC
9500 Ray White Road, Suite 200
Fort Worth, TX 76244
Fax: 817-953-7000
Email: kwallace@kwlawfirm.net
Bar Status: Admitted/In Good Standing
Cenlar FSBrepresented byMelissa S Gutierrez
Bradley Arant Boult Cummings LLP
600 Travis Street, Suite 4800
Houston, TX 77002
Fax: 713-576-0301
Email: mgutierrez@bradley.com
Bar Status: Admitted/In Good StandingJon H Patterson
Bradley Arant Boult Cummings LLP
One Federal Place
1819 Fifth Ave North
Birmingham, AL 35203
Email: jpatterson@bradley.com
Bar Status: Admitted/In Good Standing
CitiMortgage, Inc.represented byMelissa S Gutierrez
(See above for address)
Bar Status: Admitted/In Good StandingJon H Patterson
(See above for address)
Bar Status: Admitted/In Good Standing


Date Filed#Docket Text
04/13/20221NOTICE OF REMOVAL filed by CitiMortgage, Inc., Cenlar FSB. (Filing fee $402; receipt number 0539-12749740) In each Notice of Electronic Filing, the judge assignment is indicated, and a link to the Judges Copy Requirements and Judge Specific Requirements is provided. The court reminds the filer that any required copy of this and future documents must be delivered to the judge, in the manner prescribed, within three business days of filing. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms and Instructions found at www.txnd.uscourts.gov, or by clicking here: Attorney Information – Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (Attachments: # 1 Exhibit(s) A, # 2 Exhibit(s) B, # 3 Cover Sheet, # 4 Cover Sheet Supplement) (Gutierrez, Melissa) (Entered: 04/13/2022)
04/14/20222ORDER REQUIRING SCHEDULING CONFERENCE AND REPORT FOR CONTENTS OF SCHEDULING ORDER: Joint Proposed Scheduling Order due by 5/12/2022. (Ordered by Judge Reed C. O’Connor on 4/14/2022) (npk) (Entered: 04/14/2022)
04/14/20223New Case Notes: A filing fee has been paid. File to: Judge O Connor. Pursuant to Misc. Order 6, Plaintiff is provided the Notice of Right to Consent to Proceed Before A U.S. Magistrate Judge. Clerk to provide copy to plaintiff if not received electronically. Attorneys are further reminded that, if necessary, they must comply with Local Rule 83.10(a) within 14 days or risk the possible dismissal of this case without prejudice or without further notice. (axg) (Entered: 04/14/2022)
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