Task: Text Completion
Input (English): officers say that Mr. Jones ignored their commands and refused to step back, id. at 17, even though Jones has denied this. Indeed, the officers expressly decline to concede Mr. Jones’ version of the facts, instead “requesting] that this Court review the record and determine the appropriate facts.” Id. at 4 n. 1. In their reply brief, it is true, the officers argue that “even relying on Jones[’] statement of events, probable cause still exists to support his arrest.” Reply Br. at 5. They.drop all references to Mr. Jones’ physical obstruction of the officers and argue that “verbal actions” alone can rise to the level of obstructing police business. Id. at 8-10. But this effort to preserve the officers’ appeal comes too late. Cf. United States v. Campbell, 279 F.3d 392, 401 (6th Cir.2002) (<HOLDING>). And significant factual issues would remain 
 Holding statements: (A) holding that reply brief is appropriate forum to rebut new material raised in appellees brief (B) holding that we do not consider arguments raised for the first time in a reply brief (C) holding that arguments raised for the first time in a reply brief are forfeited (D) holding that arguments first raised in appellants reply brief were in answer to those raised in appellees brief and therefore refusing to strike those arguments (E) holding that the appellant cannot raise new issues in a reply brief he can only respond to arguments raised for the first time in appellees brief internal quotation marks omitted
Output (English): (E)