relation back argument and issues

The following discusses the relation back arguments that were not considered by the Court :

footnote from my 9th circuit reply :

ecf 46 (detached from ecf 46) :

my supplement, ecf 47 :

The Respondent's reply, ecf 50 :

Where, "...somehow relates back...", the Respondent's fail to challenge my argument with any specifiicity.

Go sossa case law procedural defense for my additional defense argument to overcome the timeliness default :