The following excerpt is from U.S. v. Fernandez, 861 F.2d 269 (9th Cir. 1988):
3 In his reply brief, Fernandez contends for the first time that the district court erred in failing to give his proposed jury instruction on the element of knowledge in the conspiracy charge. As a general rule, issues cannot be raised for the first time in a reply brief. Thompson v. Commissioner, 631 F.2d 642, 649 (9th Cir.1980), cert. denied, 452 U.S. 961 (1981).
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