What is the proper procedure for bringing a request for judicial notice before the court?

Turning to the issue of the proper procedure for bringing the request before the court, no sufficient reason appears why a formal noticed motion pursuant to rule 41 should be required, and such a procedure appears to be contrary to the informality contemplated by the Evidence Code. ⁵ Section 459, subdivisions (c) and (d), clearly places upon the court rather than the party the duty to give the adverse party an opportunity to meet the matter to be judicially noticed. ⁶ Since the propriety of taking judicial notice will not usually be determined until the cause is being decided on the merits, we see no objection per se to a request for judicial notice being made in a brief though it is desirable in the interest of orderly judicial procedure that it be made well before that time. (See People v. Bautista, supra, 6 Cal.App.3d 344, 348--349, 85 Cal.Rptr. 688--certified copies of documents attached to the brief; People v. Phillips, supra, 229 Cal.App.2d 496, 498, fn. 3, 40 Cal.Rptr. 403--request contained in brief.)