Motions to strike are strongly disfavored. Custom Vehicles,Inc. v. Forest River, Inc., 464 F.3d 725, 727 (7th Cir. 2006) (Easterbrook,J., in chambers). For example, if a party believes that the other side's brief contains inaccurate facts or that the other side's Local Rule 56.1 statement(in summary-judgment briefing) contains an unsupported assertion, then the complaining party should make that argument in the response or reply brief.

Likewise,the Court recognizes that raising arguments for the first time in a reply brief is dirty pool.  In re Leventhal, 2012 Bankr. LEXIS 1328, *9 n. 3 (N.D. Ill.2012).  The Court is capable of seeing that practice for what it is.  There is no need to file a motion to strike the reply brief.  Indeed, motions to strike should be constrained to their limited scope as identified in Federal Rule of Civil Procedure 12(f).