Majority
p. 575John Costin, Respondent, v Dolores Costin, Appellant. [638 NYS2d 786]
Bifurcation of matrimonial actions is generally disfavored because it raises the possibilities of economic coercion, two protracted proceedings, or delay in resolving the financial issues (Campbell v Campbell, 171 AD2d 720 ; Fiorella v Fiorella, 132 AD2d 643 ). Absent concrete reasons for bifurcation, such a motion should be denied (see, Campbell v Campbell, supra, at 721 ). Here, the only reason the plaintiff offers is that the
p. 576
grounds phase would progress quickly and the equitable distribution phase would be more complicated. Such a reason does not warrant bifurcation and could well lead to a delay in resolving the financial issues. Bracken, J. P., Balletta, Thompson and Hart, JJ., concur.
Cases cited
- Campbell v. Campbell 171 AD2d 720 p. 575
- Fiorella v. Fiorella 132 AD2d 643 p. 575