[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION TO BIFURCATE TRIAL
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for an order bifurcating trial pursuant to Fed. R. Civ. P. 42(b).

This Motion is based on the accompanying memorandum, declarations, the pleadings on file, and such other argument or evidence as may be presented.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Bifurcation is appropriate because it will promote convenience, avoid prejudice, and improve efficiency by trying [LIABILITY/DAMAGES/ISSUE 1] separately from [ISSUE 2].

II. Background

• Claims and defenses: [SUMMARY].
• Issues proposed for separate trials: [ISSUES].
• Estimated time savings: [DETAILS].

III. Legal Standard

Rule 42(b) permits the Court to order separate trials of issues or claims to further convenience, avoid prejudice, or expedite and economize.

IV. Argument

A. Bifurcation will avoid prejudice.
[Explain potential prejudice without bifurcation.]

B. Bifurcation will promote efficiency.
[Explain savings in trial time or discovery.]

C. No party will be unfairly disadvantaged.
[Explain how the proposed structure preserves rights.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Order separate trials on [ISSUE 1] and [ISSUE 2].
2. Set the sequence of trials as [ORDER].
3. Establish an amended schedule consistent with bifurcation.

CONCLUSION

For the foregoing reasons, the Court should grant the Motion to Bifurcate.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Bifurcate on all counsel of record via [METHOD OF SERVICE] in compliance with Fed. R. Civ. P. 5.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion to Bifurcate, ORDERS as follows:
1. The Motion is GRANTED.
2. Trial shall be bifurcated as follows: [DETAILS].
3. The Court will set a schedule consistent with this Order.

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
United States District Judge