In the middle of a foreclosure case dog fight.

I have a offical certificate of the formation date of the trust that is over 3 months AFTER I closed which would of course make the transfer of title to the plaintiff a impossibility.

I have filed admissions and interogatories were they dance around the issue I realize they are not going to admit to it.

I want to file a motion for judicial notice.

My question is when I file the notice do I also include striking various pleadings of the plaintiff or do I file that After I get the court to take notice?

I hope I am being clear.

Thanks