Can a jury trial be bifurcated?

Ontario, Canada

The following excerpt is from Blanchette v. Squires, 2009 CanLII 43101 (ON SC):

In Kovach v. Kovach (supra), the court, after reviewing earlier cases, stated that it was not prepared to conclude that under no circumstances may a jury trial be bifurcated yet the court stated [at para. 49] that "a jury trial can never be bifurcated unless all the parties to the action consent". In the present action, there is no Jury Notice filed in the third- party proceeding, however, there is one in the main action.

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