Answer the following problem, briefly explaining your answer.

Manley issued a $20,000 negotiable note to Preston to pay for a parcel of land. Preston misrepresented to Manley that the parcel contained 50 acres, when in fact it contained only 40 acres. Preston negotiated the note to Carl. Carl paid Preston $20,000 for the note, and he took it without notice of Preston's fraud. Later, Carl negotiated the note to Ned who knew that Manley claimed that he had been defrauded.

1. Is Carl a holder in due course?

2. Manley's defense of fraud is what type of defense?

3. Can Manley assert this defense against Ned?