Whether a party can take judicial notice of documents without identifying the purpose, material to be recognized, and grounds under Fed. R. Evid. 201(e)

QUESTIONS PRESENTED 1. Fed. R. Evid. Rule 201 and caselaw gives the parties the ability to enter } documentary evidence through judicial notice; under what conditions can a party, | without identifying the purpose of the documents, the material in the documents to be | recognized, the grounds for taking judicial notice, with the court, ignoring the requested judicial notice process of Fed, R. Evid. 201(e), take judicial notice of documents? 2. If a trial court rejects a party’s preliminary motions, such as a motion to dismiss, of | that party, but both the trial court and the appellate court of that jurisdiction decides, based on the moving party’s submitted documents, that the case, to be efficiently dealt | with, should be refiled in another jurisdiction and thereafter, the case is dismissed | pursuant to the forum non conveniens doctrine. If, pursuant to orders from both the trial court and appellate court, the same case was refiled in the court mandated new | jurisdiction, would there be Cross Jurisdictional Forum Non Conveniens Preclusion bars that prohibited the rehearing of decided preliminary motions in the new jurisdiction? : 3. Are out of court disparaging communications made by a defendant, at an earlier time, to a beneficiary’s who is later in litigation with his beneficiary and there are also communications between a defendant and third parties not in litigation, exempt from a defamation suit against the present defendant via litigation privilege? | ii I,