[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION TO BIFURCATE TRIAL

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 to bifurcate the trial and separately try [ISSUE 1] and [ISSUE 2].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

Bifurcation will promote judicial economy, avoid prejudice, and streamline the presentation of evidence.

II. Background

• Claims and defenses: [SUMMARY]
• Issues proposed for separate trial: [ISSUES]
• Estimated trial length and witnesses: [SUMMARY]

III. Legal Standard

Courts may order separate trials of issues or claims for convenience, to avoid prejudice, or to expedite and economize the proceedings.

IV. Argument

A. Separate trials will promote efficiency.
[Explain how bifurcation reduces time and complexity.]

B. Bifurcation will avoid prejudice.
[Identify potentially prejudicial evidence that can be segregated.]

C. The issues are distinct and can be tried separately.
[Explain separability and minimal duplication.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Order separate trials for [ISSUE 1] and [ISSUE 2].
2. Set a schedule for each phase of trial.

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].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered the Motion to Bifurcate, ORDERS as follows:
1. Trial is bifurcated to separately address [ISSUE 1] and [ISSUE 2].
2. A schedule for each phase is set forth in the Court's case management order.

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge