Does a cross-appellant's reply brief need to address issues raised in the appellant's combined brief?

¹⁵ We limit our discussion of Abatti's arguments to issues properly raised in his combined brief. The District and Abatti briefed the parties' rights in connection with the District's appeal. However, Abatti devoted much of his cross-appellant's reply brief to the issue, including addressing the reply portion of the District's combined brief, under the guise of "establishing the ... water rights" to show that the breach and taking claims have merit. We do not consider these points. (Hawran v. Hixson (2012) 209 Cal.App.4th 256, 268, 147 Cal.Rptr.3d 88 [cross-appellant " may not use its cross-appellant's reply brief to answer points raised in the appellant's reply brief. "].) We also do not consider arguments newly raised in the amicus answer briefing. In addition, Abatti stated in his combined brief that "the [District's] [f]armers have pre-1914 water rights," but explained in a petition for rehearing that he is asserting an interest in the District's water rights, not legal title to pre-1914 rights. We accept the clarification.