Bulgari v. Bulgari

Background

Ilaria Bulgari, identified as both the plaintiff and a counterclaim-defendant, requested a trial date for her affirmative claims. The court treated that request as a motion for separate trials under Federal Rule of Civil Procedure 42(b). Veronica Bulgari, identified as both the defendant and a counterclaim-plaintiff, opposed the request. Veronica also moved to strike Ilaria’s jury demand, and Ilaria opposed that motion.

Discovery on Ilaria’s claims was complete. Fact discovery on the counterclaims was scheduled to close on June 6, 2025, and summary-judgment motions were anticipated afterward.

Separate-Trial Motion

Rule 42(b) permits a court to order separate trials to promote convenience, avoid prejudice, or expedite and reduce the cost of litigation. The party seeking separate trials bears the burden of showing that they are justified.

The court concluded that Ilaria had not shown that separate trials would conserve resources or make the trial more efficient. The surviving claims and counterclaims arose from the same background facts involving the administration and distribution of the family’s assets, the same coordinated estate structure, and many of the same witnesses. The claims and counterclaims also involved the same legal issue: alleged breaches of fiduciary duty in administering a family trust. Because the issues and evidence overlapped, separate trials could require duplicative presentations of evidence and witnesses.

The court also found that Ilaria had not shown enough prejudice to justify separate trials. Although delayed litigation could increase costs and delay resolution, separate overlapping trials could also increase costs. The court determined that any minimal prejudice from delay did not outweigh the efficiency benefits of avoiding duplicative proceedings.

Jury Demand

The court declined to decide whether Ilaria’s jury demand should be stricken at this stage. The availability of a jury trial depends on the claims and parties that ultimately remain for trial. The court noted that the Seventh Amendment preserves a jury-trial right for civil claims seeking legal remedies.

Veronica argued that Ilaria, as a non-citizen, lacked sufficient voluntary connections to the United States to claim Seventh Amendment protection. Veronica also argued that Ilaria’s fiduciary-duty claims were equitable rather than legal. Ilaria argued that she had substantial voluntary connections to the United States through prior residence, property ownership, and continuing financial and legal interests, and that she sought legal remedies including compensatory and punitive damages.

The court also noted that Third-Party Defendant Jan Boyer had not yet answered but had stated that he would request a jury trial on the claims against him. The court stated that Boyer’s citizenship and the third-party claim raised a substantial question about whether that claim independently triggered a constitutional jury-trial right. The court found that the issue would be better resolved after any summary-judgment motions on Veronica’s claims against Ilaria and Boyer, when the claims and parties for trial would be clearer.

Disposition

The court ordered that Ilaria’s motion for a separate trial was DENIED. It ordered that Veronica’s motion to strike Ilaria’s jury demand was DENIED without prejudice to renewal after resolution of any summary-judgment motions on Veronica’s claims. This order did not resolve the underlying fiduciary-duty claims.