If the State files an answer brief, the pro se party should carefully read it and take notes to outline the arguments that are made in the answer brief. The pro se party is not required to file a reply brief and, therefore, should determine if he needs to respond to any of the State’s arguments. If the pro se party decides to respond, then the pro se party does so by filing a reply brief. The reply brief is due 20 days after the answer brief is served. If the answer brief was sent by mail or e-mail, then five more days are added to the due date of the reply brief. Like the initial brief, it also contains a table of contents, table of citations, summary of argument, argument, conclusion, a certificate of service, and certificate of typeface compliance. It is not necessary to include another statement of the case or facts. The reply brief may do so, however, if doing so is necessary to refute facts stated in the answer brief. The reply brief is limited to 15 pages, not including the table of contents, the table of authorities and the certificate of service. The reply brief is supposed to respond to the State’s answer brief arguments. It is not supposed to merely restate the argument from the initial brief, and it cannot raise new arguments that were not raised in the initial brief. Reply briefs are addressed in more detail in Chapter 5 on Writing an Appellate Brief.