Let $R \subset S$ be distinct non-type-I von Neumann factors; say two projections $P, Q \in S$ "meet" if they have a common non-null subprojection (i.e. if $P \wedge Q \neq 0$), and call $P$ "$R$-disjoint" if $P$ meets no projection in $R$ except the identity: Must $S$ have a (non-null) $R$-disjoint projection?
For "split inclusions," where there exists a type I factor $N$ such that $R \subset N \subset S$, the answer is yes (there is a *-isomorphism $\phi : N \rightarrow B(K)$ for some Hilbert space $K$; consider a projection in $P \in N$ such that $\phi(P)$ is a one-dimensional projection along a vector $v \in K$ that is separating for $\phi[R]$); so this question is really about non-split inclusions.