Subrosa surveillance—also known as covert video taken of a plaintiff—is a common tactic in personal injury cases. In this video, trial attorney Mike Alder shares how to handle it strategically and legally.

Mike breaks down:
What parts of surveillance are protected under work product privilege—and what isn't
How to discover the existence of surveillance, even if the video itself isn’t disclosed
The importance of form interrogatories and supplemental discovery under California law
How to anticipate when surveillance is most likely to occur (hint: medical exams and just before trial)
Ways to challenge and exclude last-minute surveillance footage at trial
Tactics for cross-examining surveillance videographers who spent days filming but only captured a few seconds

Mike also offers practical tips on requesting privilege logs, issuing trial subpoenas, and leveraging surveillance gaps in court. For sample discovery language, subpoena templates, or motions in limine related to subrosa, viewers are encouraged to reach out. His contact info is in the bio.

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About AlderTalk:
Michael Alder shares his knowledge gained from 30+ years in litigation in Personal Injury. His tips and conversations are dedicated to Lawyers of all experience levels.

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