NOTICE OF FILING “DEFENDANT'S 3rd REQUEST FOR COMPULSORY JUDICIAL

NOTICE”.
(w/attachment)

COMES NOW, Defendant, Jason Stoddard, a cestui que trust, (“defendant”) , doth hereby files &
serves this NOTICE OF FILING on Plaintiff pursuant to Florida Statute 90.203 (1)(2)
“DEFENDANT'S 3rd REQUEST FOR COMPULSORY JUDICIAL NOTICE”(attached)

CERITIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing notice and the “DEFENDANT'S 3rd
REQUEST FOR COMPULSORY JUDICIAL NOTICE :were sent and served on Plaintiff and all other
pertinent parites, via e-filing and/or email (see service list)on this 2/2/2023.

JASON STODDARD
e-Conformed by_/s/Jason Soddard
Jason Stoddard, Cestui que trust
28936 stormcloud pass
wesley chapel,fl 33543
J.T&K.WRy.Co. Parcel #6 ph
(202) 681-5459
ELECTRONIC MAIL: HDCOOPEROFMIAMI@GMAIL.COM
service list: eservice@mcclainalfonso.com, dalfonso@pasoclerk.com, crcive1@jud6.org

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 DEFENDANT'S 3rd REQUEST FOR COMPULSORY JUDICIAL NOTICE

COMES NOW, Defendant, Jason Stoddard, a cestui que trust, (“defendant”) ,by preserved “special
appearance”, doth hereby moves, and where appropriate, demands and/or”request” this court to take
compulsory JUDICAIL NOTICE pursuant to Florida Statute 90.201, 90.202, & 90.203 and presents the
following Matters which must be judicially noticed and states and request compulsory judicial notice for all
other matters for the purpose of all pending motions, subsequent filings and proceedings, -- the following
documents , precedent and laws which are matter of public record-- as they indicate the endorsement
appearing on Plaintiff's note is a NULLITY in this matter , effectively barring this action as a matter of law for
want of standing in Plaintiff and lack of Subject matter jurisdiction in this court, accordingly, Defendant
states;

FACTS (Fl Stat. 90.202n(6) (11) (12) )

1. These facts are not subject to dispute because they are generally known within the territorial

jurisdiction of the court, and these facts are not subject to dispute because they are capable of

accurate and ready determination by resort to sources whose accuracy cannot be questioned.

2. Plaintiff filed this frivolous suit on 02/28/2019. Dkt 5.

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 3. Plaintiff attached a copy of a note purporting to have an undated “endorsement in blank” signed

by a DAVID A SPECTOR, MANAGING DIRECTOR(“SPECTOR”) , Dkt.5, Exhibit “A”

which has been used to fabricate standing.

4. On 06/07/2019, Defendant filed an answer (Dkt 56) SPECIFICALLY denying the validity of

every signature of every document submitted by Plaintiff putting the authenticity and validity at

issue, thus, placing an evidentiary burden of proof on Plaintiff to prove the validity and

authenticity of the purported “endorsement”, See,” AFFIRMATIVE DEFENSES PREAMBLE”

section of Dkt 56, ¶ 27.

5. In order to meet that steep burden of proof and prove “standing”1, Plaintiff would have to have

attached evidence to Plaintiff's pleading indicating said endorsement was placed on the note

prior to the termination of the alleged endorsers (SPECTOR) employment at COUNTRYWIDE

HOME LOANS, INC.(“CW”) --for the public record CLEARLY shows(as this motion will

point to) that SPECTOR ceased his employment at CW in late 2006, and that the purported

“endorsement” did not appear on said note till sometime after 2014, and therefore, the note has

not been negotiated or endorsed as a matter of law, and therefore Plaintiff lacks standing.

6. Also , Defendant specifically alleged said endorsement is a forgery and that the note had

therefore been discharged by material alteration 2,this goes to the courts jurisdiction to hear this

matter. (See Id. @ ¶¶ 45, 46).

7. Recording – the act of putting a document into official county records – is an important process

that provides a traceable chain of title to a property(the note) , in this case, Plaintiff's”original”

note was recorded (unendorsed) twice, once in this court in 2008,

1 @Dkt 56; ¶ 47—the issue of Plaintiff's standing was raised.

2 Under UCC Section 3-407, if a holder materially and fraudulently alters an instrument, any party whose contract is
affected by the change is discharged. 

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 (case#:512008ca006903caaxes) and Federal court 2009, (case #: 8:09-Bk-00338-MGW).

8. Neither of the publicly recorded notes show an endorsement , indicating that: 1) the notes had

been negotiated to Plaintiff. 2) that Plaintiff was the holder of the note 3) Plaintiff has standing

4) this court has jurisdiction to hear this matter.

9. The public record clearly shows the purported endorsement was not made prior to to 2006 as

would be required by law for Plaintiff to have standing to bring this action and this court to

have jurisdiction to hear it.

10. The public record shows, --that Plaintiff acquired the alleged “original note” sometime after

2008, (2 years after SPECTOR ceased employment with CW), said note was NOT endorsed

indicating it had not been negotiated to Plaintiff, but instead, Plaintiff had come about the note

in some presumably nefarious fashion, and that sometime after retrieving the unendorsed note

from this courts coffers3 , and because Plaintiff has remained in possession of said note, it is a

reasonable inference, based on the reason person standard, that Plaintiff forged the

endorsement, illegally converting said note into a bearer instrument.

11. This court has a duty to verify records to identify forged instruments4.

12. Forgery is defined as making or altering a document with the intent to injure or defraud another person. Uttering is

presenting the document with the intention to defraud some other person. Here, the instrument, while in

possession of Plaintiff, was unendorsed, and while still in possession of Plaintiff the

endorsement has appeared, therefore, it is a reasonable inference that Plaintiff in fact forged the

purported endorsement. This note at a minimum, is not reliable as evidence, nor is it admissible

3 See case #; 512 008ca006903caaxes Dkt. 63

4 § 3-406. NEGLIGENCE CONTRIBUTING TO FORGED SIGNATURE OR ALTERATION OF INSTRUMENT. (a) A person whose failure to exercise
ordinary care substantially contributes to an alteration of an instrument.

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 as evidence conferring standing in Plaintiff.

13. The signature purporting to be an endorsement, is at the very least “unauthorized”. 5

14. In pertinent part , --a schedule of the 2008 case #: 512008ca006903caaxes is attached hereto.

EXHIBIT “A” .

15. In pertinent part, a copy of the alleged “original note”(signature bar) filed into case #:

512008ca006903caaxes Dkt. 38 is attached hereto. EXHIBIT “B”.

16. In pertinent part –a copy of the alleged “original note”(signature bar) filed into Federal case #:

8:09-Bk-00338-MGW is attached hereto. EXHIBIT “C”.

17. DAVID A. SPECTOR terminating employment with COUNTRYWIDE HOME LOANS, INC.

has been published in numerous public sites, including but not limited to 'MORGAN

STANLEY”, EXHIBIT “D” .

18. The above stated facts are Facts that are not subject to dispute because they are generally known

within the territorial jurisdiction of the court and because they are capable of accurate and

ready determination by resort to sources whose accuracy cannot be questioned.

19. Florida Statute 90.203 sets out in pertinent part:  Compulsory judicial notice upon

request.—A court shall take judicial notice of any matter in s. 90. 202 when a party

requests it and gives each adverse party timely written notice of the request, proof of

which is filed with the court, to enable the adverse party to prepare to meet the request

and furnishes the court with sufficient information to enable it to take judicial notice of

the matter.

5 § 3-403. UNAUTHORIZED SIGNATURE. (a) Unless otherwise provided in this Article or Article 4, an unauthorized signature is ineffective except as
the signature of the unauthorized signer 

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 20. Judicial Notice prevents a party from having to prove what is already know, See Shriver

v. Tucker, 42 So. 2d 707 (Fla. 1949), -Huff v. State, 495 So. 2d 145, 151 (Fla. 1986)- --

Maradie v. Maradie, 680 So. 2d 538 (Fla. 1st DCA 1996)

21. . A court may take judicial notice of facts that are not subject to dispute and that are

capable of accurate and ready determination by resort to sources whose accuracy cannot

be questioned. See Maradie v. Maradie, 680 So. 2D 538, 542 (Fla. 1st DCA 1996) .

Furthermore, pursuant to Section 90.202(6) , a court may take judicial notice of various

matters including “[r]ecords of any court of this state or any court of record of the

United States or of any state, territory, or jurisdiction of the United States. “ Dufour v.

State, 69 So. 3Rd 235 , 253 (Fla. 2011(Citing Fl Statute 90.202(6) (2018)).

WHEREFORE, Defendant respectfully request that this Honorable court take compulsory
judicial notice of the matter stated herein and Sua Sponte involuntarily dismiss with prejudice
this action or in the alternative, notice and consider the matter stated herein for any motions
made by Defendant.
CERITIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the forgoing notice and the 'REQUEST
FOR COMPULSORY JUDICIAL NOTICE” were sent and served on Plaintiff and any other
pertinent party in compliance to Fl. Stat. 90.203(1)(2) via e-filing and/or email on this
2/2/2023.
JASON STODDARD
e-Conformed by_ /s/Jason Soddard
Jason Stoddard, Cestui que trust
28936 stormcloud pass
wesley chapel,fl 33543
J.T&K.WRy.Co. Parcel #6 ph
(202) 681-5459
ELECTRONIC MAIL: HDCOOPEROFMIAMI@GMAIL.COM
eservice@mcclainalfonso.com, dalfonso@pasoclerk.com, crcive1@jud6.org

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 EXHIBIT “A”

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 EXHIBIT “ B”
Signature bar from the state 2008 case showing the note was not endorsed.

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10Of 14 DEFENDANT'S 3rd REQUEST FOR COMPULSORY JUDICIAL NOTICE 07:36:43 AM 02/02/23
 EXHIBIT “D”

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12Of 14 DEFENDANT'S 3rd REQUEST FOR COMPULSORY JUDICIAL NOTICE 07:36:43 AM 02/02/23
 EXHIBIT “C”

Signature bar from the alleged “original note” filed into Federal cas #: 8:09-Bk-00338-MGW

this shows that there was no endorsement in 2009 either.

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