such claims on behalf of the other class members demonstrates that her claims may not be typical of other class members and that she may not be an adequate representative of the interests of class members who were employed outside New Jersey. See Fed.R.Civ.P. 23(a). 10 . In her reply brief. Reap seeks to amend her motion to include a request for alternative certification of the subclass of females over the age of 40 under the provisions of Section 16(b) of the Fair Labor Standards Act. (See Pl.'s Reply Br. in Supp. of Her Mot. for Class Certification at 2.) ”[I]t is improper for a party to present a new argument in his or her reply brief.” United States v. Medeiros, 710 F.Supp. 106, 110 (M.D.Pa.), aff'd, 884 F.2d 75 (3d Cir.1989); Cf. United States v. Boggi, 74 F.3d 470, 478 (1996) (<HOLDING>). CNA has not had the opportunity to adequately
holding that courts of appeals will generally not consider arguments raised on appeal for first time in reply brief holding court will generally not consider arguments presented for the first time on appeal holding that we do not consider arguments raised for the first time in a reply brief holding that arguments raised for the first time in a reply brief are forfeited holding that in the absence of manifest injustice the court will not consider arguments raised for the first time in appellants reply brief