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Our case law is “well established that a lis pendens may not be predicated on an action or suit for a money judgment but applies only to an action or suit which directly affects the title to real property.” Coventry Homes, Inc., 155 Ariz. at 217; (seeking real property to recover debt “does not turn the dissolution action into an action affecting real property”).

DISCUSSION ¶11 When reviewing the denial of spousal maintenance, this court accepts “the trial court's findings of fact unless clearly erroneous and draw[s] our own legal conclusions based on those facts.” ¶ 6 (App. 2018) (-72 (App. 1997)).

An enforceable contract requires “an offer, acceptance, consideration, a sufficiently specific statement of the parties’ obligations, and mutual assent.” ¶ 10 (App. 2019) ().

See Hill-Shafer P’–74 (1990)

(stating that as a contract, a settlement agreement is based on contract principles of "an offer, acceptance, consideration, a sufficiently specific statement of the parties' obligations, and mutual assent" and courts may look to the parties' conduct in deciding "whether a meeting of the minds occurre

(stating that when an appellate decision “substantially alters the status of the decree as written,” the trial court may reconsider related issues on remand).

¶10 A marital separation agreement is a contract, see Muchesko v. Muchesko , , 268, , 24 (App. 1997), and when a property settlement agreement is incorporated into a decree, contract law governs the agreement, MacMillan v. Schwartz , , 588, ¶ 12, , 1217 (App. 2011).

“Arguments raised for the first time in a reply brief are deemed waived.” ¶ 25 n.5 (App. 2000) ().

Muchesko v. Muchesko , , 271-72

thout a l[i]cense; has criminal history; no billing presented; coercion & intimidation used, and more” are “most certainly factual allegations.” Because Earle did not raise these arguments in his opening brief, “[w]e will not consider arguments made for the first time in a reply brief.” ¶91, ( ).

(citing Savoca Masonry Co. v. Homes & Son Constr.

¶ 91 , (“We will not consider arguments made for the first time in a reply brief.”) ( , ).

n.4, ¶ 17 (App. 2008) ( n.2, ¶ 22 (App. 2005), ).

(treating improper appeal as special action and accepting jurisdiction to address merits of argument).

See Savoca Masonry Co. v. Homes & Son Constr., , , (holding that an attorney-proffered offer may bind the client).

n. 2 , , 695 n. 2 (App.2005); , (noting cases from other jurisdictions would not be considered when cited for first time in reply brief).