there is no Notes functionality to do the trick. You have to use a Windows API function to get a handle to the Notes window and bring it to the front. Here is the function to get a handle to the window:
Declare Function FindWindow Lib “user32” Alias “FindWindowA” (Byval
lpClassName&, Byval lpWindowName$) As Long
Just search the web to get examples for activating a background window with script and API calls.