Fourth Court of Appeals San Antonio, Texas October 7, 2020 No. 04-20-00059-CR Marcelino ESTRADA, Appellant v The STATE of Texas, Appellee From the 81st Judicial District Court, Atascosa County, Texas Trial Court No. 17-09-0519-CRA Honorable Russell Wilson, Judge Presiding

ORDER Sitting: Luz Elena D. Chapa, Justice Irene Rios, Justice Beth Watkins, Justice Appellant’s final motion to extend time to file the appellant’s brief is granted. We order counsel for appellant to file the appellant’s brief by November 16, 2020. Counsel has represented to this court that no further motions for an extension will be filed. Counsel is therefore advised that no further extensions of time will be granted absent a timely motion that: (1) demonstrates extraordinary circumstances justifying further delay; (2) advises the court of the efforts counsel has expended in preparing the brief; and (3) provides the court reasonable assurance that the brief will be completed and filed by the requested extended deadline. The court does not generally consider a heavy workload to be an extraordinary circumstance.

_________________________________ Luz Elena D. Chapa, Justice