The question is how do you get to that list view? If you start from a record that holds the Foreign Key you need I would suggest setting that foreign key either ina persistent variable "$$ForeignKey" Or I would set it in a global field in the table the list view is based on.
You would do this just before going to the list layout.
Then anyone can do whatever they want in that list and when they create a new note you can still take the Foreign Key from the global field.
Also is it maybe possible to display the notes in a portal? Then you can create a "New Note" button on the record that actually contains the foreign key.
Or you could just create a new note in the portal and you wouldn't even have to worry about setting the FK.