California, United States of America
The following excerpt is from Lister v. Bowen, 155 Cal.Rptr.3d 50, 215 Cal.App.4th 319 (Cal. App. 2013):
Campos v. Anderson (1997) 57 Cal.App.4th 784, 794, fn. 3, 67 Cal.Rptr.2d 350 [[p]oints raised in the reply brief for the first time will not be considered, unless good reason is shown for failure to present them before].)
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