California, United States of America
The following excerpt is from Abrew v. Abrew (In re Abrew), A144141 (Cal. App. 2017):
9. Heather appears to request attorney's fees on appeal for the first time in her reply brief, but this request, too, has been forfeited, for failure to raise it in the opening brief. (People v. Tully (2012) 54 Cal.4th 952, 1075 ["It is axiomatic that arguments made for the first time in a reply brief will not be entertained because of the unfairness to the other party."].)
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