How have the courts considered arguments raised for the first time in a reply brief?

MultiRegion, United States of America

The following excerpt is from Lopez v. Cook, Civ. No. S-03-1605 KJM DAD, Civ. No. S-09-1760 MCE AC (E.D. Cal. 2014):

The court declines to consider this argument. First, if it "need not consider arguments raised for the first time in a reply brief," Zamani v. Carnes, 491 F.3d 990, 997 (2007),

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