Bolde v. Navistar, Inc. et al.

Defendant Navistar, Inc.’s Motion to Bifurcate Liability from Damages at Trial is DENIED.

Code of Civil Procedure section 598 provides that the Court may order that the trial of any issue shall precede the trial of any other issue “when the convenience of witnesses, the ends of justice, or the economy and efficiency of handling the litigation would be promoted thereby.” Section 1048(b) provides: “The court, in further of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial on any cause of action . . . or of any separate issue or any number of causes of action or issues . . . .”

The Court concludes that judicial economy will not be served by ordering separate trials on liability and damages. In assigning personal injury cases for trial, Department 1 acts as a master calendar court. In the master calendar context, ordering bifurcation presents logistical challenges for the Cour