1 Your name

Your address
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[City, ST ZIP Code]
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[COURT NAME]
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[PLAINTIFF'S NAME], Case No.: [Number]
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Plaintiff,
8
NOTICE OF OBJECTION
vs.
9 FEDERAL RULES OF EVIDENCE
201(D) JUDICIAL NOTICE OF
[DEFENDANT'S NAME],
10 EVIDENCE OF AN ADJUDICATED
Defendant FACT TRINSEY V PAGLIARO, 229
11
F. SUPP. 647 - DIST. COURT, ED
12 PENNSYLVANIA 1964
“STATEMENTS OF COUNSEL IN
13 THEIR BRIEFS OR ARGUMENT
WHILE ENLIGHTENING TO THE
14 COURT ARE NOT SUFFICIENT
FOR PURPOSES OF GRANTING A
15
MOTION TO DISMISS OR
16 SUMMARY JUDGMENT.”

17

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NOTICE OF OBJECTION FEDERAL RULES OF EVIDENCE 201(d)
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COURT TAKE JUDICIAL NOTICE OF EVIDENCE OF AN
20
NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 1
 1 ADJUDICATED FACT THAT REQUIRES THIS COURT HONOR
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PRECEDENT TO DISMISS ANY DISMISSALS BY COUNSEL
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WHETHER BY BRIEFS OR ARGUMENTS BECAUSE THEY ARE NOT
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FACTS BEFORE THE COURT Trinsey v. Pagliaro, 229 F. Supp. 647 -
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Dist. Court, ED Pennsylvania 1964 “Statements of counsel in their briefs or
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7 argument while enlightening to the Court are not sufficient for purposes of

8 granting a motion to dismiss or summary judgment.” Trinsey v. Pagliaro, 229

9
F. Supp. 647 – Dist. Court, ED Pennsylvania 1964
10

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1. Objection, court must take judicial notice of evidence of an adjudicated fact
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in support of the court’s requirement to dismiss any motion for dismissal by
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14 counsel for failure to state a claim under federal rule 12(b)(6) by counsel.

15 “Statements of counsel in their briefs or argument while enlightening to the

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Court are not sufficient for purposes of granting a motion to dismiss or
17
summary judgment.” Trinsey v. Pagliaro, 229 F. Supp. 647 – Dist. Court,
18
ED Pennsylvania 1964
19

20
NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 2
 1 2. Objection, court must take judicial notice of an adjudicated fact that
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attorneys cannot testify, therefore without witness testimony or evidence
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introduced by the petitioner to prove the respondent caused an injury in fact
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the court is without jurisdiction to prosecute. ”Attorneys can't testify;
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statements of counsel in brief or in oral argument are not facts before the
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7 court.” United States v. Lovable 431 U.S. 783,97 S. 2004, 52 L. Ed. 2d 752

8 and Gonzales v. Buist 224 U.S. 126. 56 L.. 693. 32. Ct. 463.S.
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3. Objection, court must take judicial notice of an adjudicated fact that it is a
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constitutional minimum of standing requiring the petitioner to introduce
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evidence of a injury in fact or the court cannot prosecute. “Over the years,
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our cases have established that the irreducible constitutional minimum of
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14 standing contains three elements. First, the plaintiff must have suffered an

15 "injury in fact"—an invasion of a legally protected interest which is (a)

16
concrete and particularized, see id., at 756; Warth v. Seldin, 422 U. S. 490,
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508 (1975); Sierra Club v. Morton, 405 U. S. 727, 740-741, n. 16 (1972);[1]
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and (b) "actual or imminent, not `conjectural' or `hypothetical,' " Whitmore,
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supra, at 155 (quoting Los Angeles v. Lyons, 461 U. S. 95, 102 (1983)).
20
NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 3
 1 Second, there must be a causal connection between the injury and the
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conduct complained of—the injury has to be "fairly. . . trace[able] to the
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challenged action of the defendant, and not . . . th[e] result [of] the
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independent action of some third party not before the court." Simon v.
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Eastern Ky. Welfare Rights Organization, 426 U. S. 26, 41-42 (1976). Third,
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7 it must be "likely," as opposed to merely "speculative," that the injury will

8 be "redressed by a favorable decision." Id., at 38, 43” LUJAN,

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SECRETARY OF THE INTERIOR v. DEFENDERS OF WILDLIFE et
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al. 504 U.S. 555 (1992)
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4. Objection, court must take judicial notice of an adjudicated fact by the
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Supreme Court “Murray's Lessee v. Hoboken Land & Improvement Co.
13

14 (1856)” that requires any deprivation of life, liberty, or property requires a

15 judgment by peers or the judgment not by peers is void for lack of due
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process therefore it is the law of the land. “The words, "due process of
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law," were undoubtedly intended to convey the same meaning as the words,
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"by the law of the land," in Magna Charta. Lord Coke, in his commentary
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on those words, (2 Inst. 50,) says they mean due process of law. The
20
NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 4
 1 constitutions which had been adopted by the several States before the
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formation of the federal constitution, following the language of the great
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charter more closely, generally contained the words, "but by the judgment
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of his peers, or the law of the land." Murray's Lessee v. Hoboken Land &
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Improvement Co. (1856)
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7 INVOKING ARTICLE 4 FULL FAITH AND CREDIT CLAUSE AND

8 PRIVILEGES AND IMMUNITIES CLAUSE

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1. It is a conclusion of law under the Full Faith and Credit Clause under
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Article 4 Section 1 of the Constitution for the United States that Full
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Faith and Credit of public records by judicial proceedings must be
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honored by every other state.
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14 2. It is a conclusion of law under the Full Faith and Credit Clause under

15 Article 4 Section 2 The Citizens of each State shall be entitled to all

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Privileges and Immunities of Citizens in the several States.
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THE COURT IS PRESENTED WITH EVIDENCE OF ADJUDICATED
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FACT AND CONCLUSIONS OF LAW BEFORE THE COURT,
19

20
NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 5
 1 THEREFORE THE COURT IS WITHOUT DISCRETION TO DISMISS
2
THIS OBJECTION
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5 Dated this [day] of [Month], [year].

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Your Name
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NOTICE OF OBJECTIONFEDERAL RULES OF EVIDENCE 201(D) JUDICIAL NOTICE OF
21 EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO, 229 F. SUPP. 647 -
DIST. COURT, ED PENNSYLVANIA 1964 “STATEMENTS OF COUNSEL IN THEIR
22 BRIEFS OR ARGUMENT WHILE ENLIGHTENING TO THE COURT ARE NOT
SUFFICIENT FOR PURPOSES OF GRANTING A MOTION TO DISMISS OR SUMMARY
23 JUDGMENT.” - 6