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The pandemic can excuse a late brief even after warning from the court.

Appellant’s brief was originally due on January 13, 2020. Upon motion, the Court ordered appellant to file his brief by May 11, 2020 and “advised appellant’s counsel that no further extension of time would be granted.” Nevertheless, appellant’s “third motion” explained “communication difficulties resulting from the COVID-19 pandemic” and resulted in yet another extension of the deadline to July 13, 2020 based upon these “extraordinary circumstances.”

Carpenter v. State, No. 03-19-0056-CR, 2020 WL 3118694 (Tex. App.—Austin June 5, 2020) (not designated for publication).