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  • United Services Automobile Subrogee of James Tyng vs. W. Vernon Whiteley Plumbing and Heating Company, Inc. Doing Business as W. Vernon Whiteley, Inc. Other Negligence - Personal Injury / Property Damage document preview
  • United Services Automobile Subrogee of James Tyng vs. W. Vernon Whiteley Plumbing and Heating Company, Inc. Doing Business as W. Vernon Whiteley, Inc. Other Negligence - Personal Injury / Property Damage document preview
						
                                

Preview

“COMMONWEALTH OF MASSACHUSETTS BARNSTABLE COUNTY, ss. : SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT Hfia afi amng “Zilla, £5. Civil Action No. 1572CV00576 HEATING COMPANY, INC. (d/b/a W. VERNON : WHITELEY, INC.) : Defendant. 2 0 d PLAINTIFF’S MOTION TO BIFURCATE ISSUES FOR TRIAL Pursuant to Massachusetts Rule of civil Procedure 42(b), Plaintiff, United Services Automobile Association (“Plaintiff”) as subrogee of James Tyng, hereby moves for an Order bifurcating the issue of liability from the issue of damages, with the issue of liability being ‘ decided by the jury first. Bifurcating the issues of damages and liability will result in convenience to the Court and to the parties and will be conducive to expedition and economy. Plaintiff submits the accompanying Memorandum of Law in support of its Motion. WHEREFORE, Plaintiff respectfully requests that the Court grant Plaintiffs Motion to Respectfully submitted, wigan yim 04 : William J. Schrnidt (pro hac vice) Shannon ae (BBO #678658) Joseph M. Kuffler (pro hac vice) 101 Arch Street, Suite 1930 Boston, MA 02110-1103 Date: April 27, 2018 Attorneys for Plaintiff Bifurcate Issues for Trial. 20787867v.1