Read the following excerpt from a US court opinion:
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(7th Cir. 2012) (“Although it is possible that the drugs found on January 18 were already in his possession as early as January 11, it is at least equally likely that they were not. For all we know, Sims sold the last of his January 11 drug supply to the officer that day and then acquired additional cocaine before his arrest on January 18.”). But Pham fails to contend, much less show, that he possessed the drugs confiscated on February 28 as early as February 12. See, e.g., Def. Br. 11 (citing Sims without tying it to this case); Reply 2 (“[U]nder these particular facts, two drug convictions, one consisting of a sale and the other of finding of the stash from that sale, warrant a finding of one criminal episode.”); see Scottsdale Ins. Co. v. Flowers, 513 F.3d 546, 553 (6th Cir. 2008) . Pham does, however, make the more complex
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What is the most suitable continuation to the opinion? Your options are:
A. holding a party waives an argument made for the first time on reply
B. holding argument is waived when raised for first time in reply brief
C. holding that arguments cannot be made for the first time in reply papers
D. holding that an argument raised for the first time in a reply brief is waived
E. holding that argument raised for the first time in reply brief was deemed abandoned
Reply with [A, B, C, D, E] only.