Goethe wrote: > [Less controversial: while the Notary might be the recordkeepor, > there is nothing that requires weekly reports of the records in > question, or indeed places any time requirements on reporting. > FALSE.]
This one is clearly trumped by Rules 2166 and 2143. The only escape I can see (apart from the Notary getting the information from ehird, and claiming EXCUSED if e doesn't provide it) is your first argument, which amounts to "the backing document contains an indirect definition of the recordkeepor that trumps its direct definition".

