Friday, February 10, 2012

FORM: Motion to Bifurcate Trial and Supporting Brief from Post-Koken Auto Accident Case

As the novel Post-Koken cases (lawsuits with combined third party negligence claims and UIM claims) begin to reach the trial level, there may be an increase in trial court decisions addressing trial related issues, including but not limited to, whether such claims should be bifurcated into two separate trials.

I recently had an opportunity to draft a Motion and a supporting Brief on a Motion to Bifurcate a consolidated Post-Koken lawsuit into two separate trials in Lackawanna County.  That issue is set to be argued on March 1, 2012.

Anyone desiring a copy of these filings as a form for future reference in the event that they may help you can contact me at

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