on November 15 to provide reasons for recounting their ballots. The next day, the Florida Supreme Court allowed manual recounts in Palm Beach and Broward Counties to continue but left it to a state judge to decide whether Harris must include those votes in the final tally. Miami-Dade County decided on November 17 to conduct a recount but suspended it on November 22. The Gore campaign sued to force Miami-Dade County to continue its recount, but the Florida Supreme Court refused to consider the request. As the manual recounts continued, the battle to certify the results intensified. On November 17, Judge Terry Lewis of Leon County Circuit Court permitted Harris to certify the election results without the manual recounts, but on the same day the Florida Supreme Court stayed that decision until it could consider an appeal by Gore. On November 21, the Florida Supreme Court ruled unanimously that manual counts in Broward, Palm Beach and Miami-Dade Counties must be included and set 5:00 p.m. on November 26 as the earliest time for certification. After that decision, the Bush campaign appealed to the U.S. Supreme Court, arguing that the state court effectively rewrote state election statutes after the vote. As the manual recounts progressed, most of Florida's counties were considering overseas absentee ballots. That part of the vote count was completed on November 18, increasing Bush's lead to 930 votes. The Palm Beach County recount and the Miami-Dade County recount (having been suspended) were still incomplete at 5:00 p.m. on November 26, when Harris certified the statewide vote count with Bush ahead by 537 votes. The next day, Gore sued under Florida's statutory construct of the "contest phase". On November 28, Judge N. Sanders Sauls of Leon County Circuit Court rejected Gore's request to include the recount results from Miami-Dade and Palm Beach Counties. Gore appealed that decision to the Florida Supreme Court. Sauls also rejected Gore's contest of the election result on December 4, and Gore appealed that decision too. On December 8, the Florida justices, by a 4–3 vote, rejected the selective use of manual recounts in just four counties and ordered immediate manual recounts of all ballots in the state where no vote for president had been machine-recorded, also known as undervotes. The U.S. Supreme Court convened on December 1 to consider Bush's appeal. On December 4, the Court ordered the Florida Supreme Court to clarify its