Delay In Asserting An Objection To Bifurcating Trial Was Dispositive.
Perceived gamesmanship can be punished; we bloggers are not the judges of whether that has happened, but we only post on what we see is decided by the courts and subject to what you readers think when reading the case. Gamesmanship, we believe, was not met with any degree of respect, as Marriage of Martinez and Camou, Case No. B345397 (2d Dist., Div. 2 July 9, 2026) (published) may well illustrate.
There, ex-wife stipulated to bifurcate a trial on the validity of a premarital agreement, then waited almost 8 months, and after participating in three separate hearings with different judges where bifurcation was discussed, to invoke her rights under European Beverages, Inc. v. Superior Court, 43 Cal.App.4th 1211, 1213 (1996) to have the same judge try all portions of a bifurcated court trial. That decision honors a bifurcation request on a premarital agreement issue, but ex-wife apparently reneged and resulted in a $20,000 monetary sanction under Family Code section 271 against her. That sanction was no abuse of discretion, given that the failure to waive European Beverages in a timely matter (as was the situation under this case)would increase costs and would not potentially aid a sooner resolution—all policies embedded in section 271, which were not met in this cause.