Can a waiting time penalty be awarded without an express finding in the special verdict that the failure to pay was willful?

^18. Defendants do not argue that a waiting time penalty cannot be awarded without an express finding in the special verdict that the failure to pay was willful. Instead, defendants, in their appellants' opening brief, apparently acknowledge that the failure to pay was willful and argue only that the failure to pay was justified. Defendants argue for the first time in their reply brief that there is no evidence that the failure to pay was willful. A reviewing court ordinarily should not consider an argument raised for the first time in a reply brief. (Reichardt v. Hoffman (1997) 52 Cal.App.4th 754, 764-766.) Defendants have shown no reason for us to deviate from that rule here, so we will not consider the point.