response brief in reply brief); Carman v. H.B. Alvord, 31 Cal.3d 318, 182 Cal.Rptr. 506, 644 P.2d 192, 195 (1982) (ruling on issue raised for first time in responsive brief and then addressed in plaintiff's reply brief); Oliveira v. Amoco Oil Co., 311 Ill.App.3d 886, 244 Ill.Dec. 455, 726 N.E.2d 51, 56 (2000) (refusing to strike arguments of appellant's reply brief that were in response to arguments first raised in appellee's brief)}; Rome v. Commonwealth Edison Co., 81 Ill.App.3d 776, 36 Ill.Dec. 894, 401 N.E.2d 1032, 1034-35 (1980) (noting that issue first addressed in appellee's brief and then answered by appellant in reply brief was not waived, but would have been if not responded to in reply brief); City of Wichita v. McDonald's Corp., 266 Kan. 708, 971 P.2d 1189, 1200 (1999) (<HOLDING>); Brashear v. Baker Packers, 118 N.M. 581, 883
holding that issue first raised in appellees brief and then answered in appellants reply brief was properly raised for review holding that reply brief is appropriate forum to rebut new material raised in appellees brief holding that the appellant cannot raise new issues in a reply brief he can only respond to arguments raised for the first time in appellees brief internal quotation marks omitted holding that an argument raised only in fact section of opening brief and in reply brief is not properly raised holding argument not raised in opening brief but raised for the first time in reply brief was waived