[JURIST] A New York judge has refused to combine former Tyco CEO Dennis Kozlowski's retrial on larceny charges with his trial on charges that he failed to pay sales taxes on art worth $13 million. New York Supreme Court Justice Michael Obus declined to combine the trials because the larceny trial, slated to begin in January, includes former Tyco CFO Mark Swartz and there is not enough evidence that Swartz was involved in the scheme to avoid payment of sales tax. Read the amended indictment [PDF] against Kozlowski and Swartz. AP has more. JURIST's Paper Chase has ongoing coverage of the Tyco trials.