With no explanation, chose the best option from "A", "B", "C" or "D". circumscribe the scope of the immunity from civil suit in light of the new criminal statute. Criminal sanctions can coexist peacefully with the absence of civil liability. In fact in this situation, Illinois courts might worry that eliminating immunity would open the doors to frivolous lawsuits, which would have a chilling effect on 911 calls. Golden contends that his claims were not frivolous because, in his view, the Illinois and municipal statutes criminalizing false 911 calls created an implied private cause of action. See 50 ILCS 750/15.2; 720 ILCS 5/26-1(a)(12); Chicago Municipal Code § 8-4-145. Thomas counters that Golden forfeited this argument by making only a brief reference to it in his motion to reconsider the judge’s order granting sanctions. See Havoco, 971 F.2d at 1336 (<HOLDING>). We agree with Thomas that the point is too

A: holding that arguments raised for the first time in a reply brief are forfeited
B: holding argument is waived when raised for first time in reply brief
C: holding argument forfeited if raised for the first time in a motion to reconsider
D: holding that an argument raised for the first time in a rule 59e motion is waived on appeal
C.