Harris issued a set of criteria by which she would determine whether to allow late filings, and she required any county seeking to make a late filing to submit to her, by 2 p.m. the following day, a written statement of the facts and circumstances justifying the late filing. Four counties submitted statements, and after reviewing the submissions, Harris determined that none justified an extension of the filing deadline. She further announced that after she received the certified returns of the overseas absentee ballots from each county, she would certify the results of the presidential election on November 18. However, on November 17, the Florida Supreme Court enjoined Harris from certifying the election while it heard appeals from the various cases in progress. On November 21, it allowed continuation of the manual recounts and delayed certification until November 26.