MEMORANDUM ON PLAINTIFF'S MOTION TO BIFURCATE
HINES, United States Magistrate Judge.
Plaintiff insurance company ("State Farm") brings this action seeking a declaratory judgment that it has no liability to the defendant ("Woods") for losses in connection with a December, 1994 fire in Jasper County. Woods has counterclaimed for benefits under the policy and for punitive damages premised on gross negligence and fraud. Woods alleges there was no investigation...
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