A motion to bifurcate is often the first line of defense in a litigated first-party insurance claim. The Defendant carrier contends bifurcation streamlines discovery and disposes of “extra-contractual” issues without having to use the court’s time and resources. In truth, however, by moving to bifurcate, the first-party insurance is trying to accomplish two major goals: 1) prevent discovery of harmful and/or “proprietary” business and/or claims file information that the insurance company knows will support an insured’s bad faith and extra-contractual claims; and 2) delay addressing the extra contractual claims by creating another hurdle for the insured to clear, i.e. a discovery and trial on the damages before allowing a discovery or trial on the merits of the extra-contractual first-party claims. The individual facts and circumstances of the case that warrant non-bifurcation should be emphasized with the court. Plaintiff should emphasize facts which could permit recovery on extracontractual claims regardless of whether or Plaintiff can prevail on the contractual claim. Plaintiff should emphasize arguments that the extra-contractual issues will have to be resolved regardless of the number of trials or the order of discovery, so in the interest of judicial efficiency, bifurcation would not be appropriate.