Opposing-Counsel Playbook: Charles & Concilio P.C.

Firm Juris No. 419050 · Connecticut · Profile built from public Connecticut Judicial Branch docket records

What this is. A data-driven scouting report on how this firm litigates contested divorce and custody cases. Every number below is computed from the firm's own filing history across the public CT family-court docket. This is a litigation-pattern analysis of public records — not legal advice, and not a claim about any individual case. Patterns describe tendencies, not guarantees.

This is general information about public litigation patterns — not legal advice, and not a recommendation about what to do in any specific case.

Snapshot

Bottom line: a well-resourced, motion-aggressive firm that is granted most of what it files in front of judges it appears before constantly. This firm's volume is its defining feature; the procedural patterns below describe how that volume shows up on the docket.

How they litigate (the style)

The signature is volume + counsel-fee leverage + contempt pressure. Three numbers define them:

• 3.21 counsel-fee requests per case (382 mentions; 28 fee motions pendente lite) — they routinely ask the court to make the other side pay their fees. For a self-represented or under-resourced opponent, this is a recurring cost-pressure pattern: litigating against the firm can carry the prospect of a fee request.
• 2.53 discovery motions per case (301 total), plus motions to compel (47) and discovery objections (54). Discovery is a heavily contested phase of these cases — the pattern is to make the process expensive and time-consuming well before the merits are reached.
• 2.05 contempt motions per case (244 total — 90 pendente lite, 88 post-judgment, 21 general) — contempt is a frequently-filed motion in their cases rather than a rare one. Allegations of order violations commonly appear early and often.

Add 3.16 continuances per case (376) and the aggregate picture is: a long timeline, a high volume of fee and contempt motions, and a docket that stays active over an extended period.

The filing barrage — and who gets it worst

Across all cases, this firm's side puts ~35.3 filings on the docket per case — a heavy paper load by any measure. The volume is not evenly distributed:

• Against a represented opponent: 37.86 filings/case. Against a pro-se opponent: 32.11/case. Either way, a self-represented spouse faces dozens of filings to track and answer with no attorney.
• The heaviest barrages on record: Bhatia v. Bhatia (FST-FA17-6032289-S) — 153 filings (the firm's all-time high); Domino v. Domino (FST-FA20-6046935-S) — 149; Fronsaglia v. Fronsaglia (FBT-FA16-6060914-S) — 128 (opponent pro se); Raveis v. Raveis (FBT-FA19-6087479-S) — 128 (opponent pro se); Gabelli v. Paganini (FST-FA23-6060700-S) — 110.
• Against self-represented opponents specifically: Fronsaglia v. Fronsaglia (FBT-FA16-6060914-S) — 128 filings; Raveis v. Raveis (FBT-FA19-6087479-S) — 128; Higbie v. Higbie (FST-FA15-5014539-S) — 108; Fine v. Fine (FST-FA19-6040604-S) — 103; Nammack v. Ponzo (FST-FA22-6055087-S) — 99. Roughly a hundred or more filings in cases against someone with no attorney.

This is the core of the attrition pattern: a large volume of filings on the docket. For a self-represented party, the section below describes the procedural tools and rules that are relevant to that asymmetry.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in 15.1% of their cases (18 of 119), and the firm logs 58 GAL-appointment events. GALs feature as a recurring element in their custody cases.
• Repeat GAL pairings: the firm repeatedly pairs with a small set of the same guardians ad litem (3 appearances each). Recurring firm–GAL pairings are a documented pattern in the docket.

What the rules provide: when a GAL is proposed, the proposed name's prior pairings with a firm are a matter of public docket record. A party may ask the court to define the GAL's scope, budget, and reporting deadline in the appointment order; an unscoped appointment is an open-ended cost and an open-ended commitment.

The bench

They appear before Hon. Donna Heller (58 rulings) most often, then Grossman (54), Kowalski (42), Colin (28), and Griffin (21). Their 81% contested-motion win rate is partly familiarity — repeated appearances mean exposure to each judge's preferences, calendar habits, and standing orders. Each judge's standing orders and motion-practice rules are part of the public record available to any party appearing before them.

What to expect — and your procedural options

This is a high-volume, motion-intensive (11 motions per case) litigation style. The items below pair each docket pattern above with the relevant Connecticut procedural tools and rules, described as information rather than direction.

1. Counsel-fee requests. Counsel fees are this firm's most frequent pressure tool (3.21 requests per case). In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own motion volume and continuance history (here, 376 continuances) are part of the litigation-conduct record the court may consider when deciding who bears cost.

1. Contempt motions. With 2.05 contempt motions per case (90 PL + 88 post-judgment), contempt is a common motion in these cases. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is what a contempt allegation is tested against; a contempt motion unsupported by the documents is one the court can deny.

1. Discovery. They file 2.53 discovery motions per case plus 47 motions to compel. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions. The motion for protective order is the procedural tool a party may use when discovery demands are excessive; documenting each response builds a compliance record.

1. Continuances and the clock. Motion for Continuance is their single most-filed motion (360). A Motion to Advance is the procedural tool a party may use to ask the court to hear a matter sooner; continuances can be opposed on the record, which requires the requesting party to justify each one.

1. The paper load. At ~35.3 filings per case (37.86 against represented opponents), the docket carries a high volume. A running index of every filing, deadline, and outcome is the standard way self-represented parties keep track of a large docket so that no motion goes unanswered for lack of tracking.

1. GAL scope. A GAL appears in 15.1% of their cases, and the firm pairs repeatedly with the same few guardians. Prior pairings are public record; the appointment order is where a court can be asked to set the GAL's scope, budget, and deadline.

1. The merits. This firm's model centers on the volume of process. A short, focused, merits-oriented record is the structural alternative — fewer motions, well-documented filings, and the substantive questions (custody, support, division) brought to the front. The firm's volume is its defining feature; a tightly-scoped record is the contrasting approach the rules permit.

Methodology & limits

Computed from public CT Judicial Branch docket entries and party rosters (parties → filing-side attribution → motion/outcome tally). "Win rate" = Granted ÷ (Granted + Denied) on the firm's own filed motions where the docket records an outcome; many entries record no outcome and are excluded. Marker counts use keyword matching on docket event descriptions and may include related sub-types. Firm-name aggregation follows the docket's recorded firm name (the source truncates long names). Patterns reflect aggregate history, not the conduct of any one attorney or the merits of any one case.