Litigation & Arbitration
Oct. 30, 2024
Sub rosa - how it's used, how to obtain it, and how to handle it
Sub rosa evidence has the potential to hurt your case. In dealing with sub rosa evidence, make sure to prepare your client and obtain the evidence during discovery. If necessary, filing a motion in limine may exclude the evidence from being presented at trial.





Shant A. Karnikian
Managing Partner and Trial Attorney
Kabateck LLP
Phone: (213) 217-5000
Email: sk@kbklawyers.com
Loyola Law School
Shant A. Karnikian is a Managing Partner and trial attorney with Kabateck LLP. His practice focuses on insurance bad faith, catastrophic personal injury, and consumer class actions.

Sheri R. Lalehzarian
Associate
Kabateck LLP
Phone: (213) 217-5000
Email: SL@KBKLawyers.com
Sheri R. Lalehzarian is an Associate at Kabateck LLP, supporting the firm's trial team in cases involving employment class actions, mass torts, consumer rights, personal injury, and wrongful death claims

Sub rosa, Latin for "under the rose," is a term used to describe surveillance done secretly. Sub rosa is often used in personal injury cases during which parties hire a private investigator (PI) to secretly record the opposing party doing activities that disprove their injury claims. For example, if a plaintiff is claiming an accident caused them back issues and they can no longer participate in daily activities, the defense may hire a PI to follow the plaintiff and record th...
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