In a federal civil trial, Plaintiff wishes to establish that, in a state court, Defendant had been convicted of fraud, a fact that Defendant denies. Which mode of proof of the conviction is LEAST likely to be permitted? 
A certified copy of the judgment of conviction, offered as a selfauthenticating document.  Testimony of Plaintiff, who was present at the time of the sentence.  Testimony by a witness to whom Defendant made an oral admission that he had been convicted. Judicial notice of the conviction, based on the court's telephone call to the clerk of the state court, whom the judge knows personally. 