I have read the latest Complaint filed on Nov 29.  It is 43 pages, and mostly a re-hash of arguments previously made. The only "new evidence" of any significance relates to BLM supposedly being made aware in 2009 of Tribal concerns relating to Kings River Valley (the location of a tribal conflict), which is outside the project area.

The issue is whether BLM made a reasonable and good faith effort to identify Tribes that should be consulted in the permitting process. Judge Du has already said it is unlikely the Tribes will prevail on this point. I dont think the "new evidence" will do much to change her mind.

But lets see how BLM/LAC respond.

Many thanks to domesticlithium for posting the documents on GitHub.