Opposing-Counsel Playbook: Conn Laborers Legal Service Fund
Firm Juris No. 402606 · 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
| Metric | Value | What it means |
|---|---|---|
| Contested cases (as P/D counsel) | 62 | A steady, multi-district family-law practice |
| Home turf | Hartford (HHD): 15, New Britain (HHB): 13, New Haven (NNH): 13, then Waterbury (7), Bridgeport (6) | Spread across central CT, anchored in the Hartford/New Britain corridor |
| Side they take | 37 plaintiff / 25 defendant | Files first more often than not — slight preference for setting the agenda |
| Motions per case | 1.71 | A measured motion practice — not a paper-blizzard shop |
| Contested-motion win rate | 76.7% (decided sample of 30 motions) | When a motion of theirs reaches a decision on the record, it is granted more often than not |
| Busiest judge | Hon. Leslie Olear (10), then Diana (5), Goodrow (4) | Familiar with the Hartford-region family bench |
Bottom line: a moderate-volume firm with a focused, file-and-decide posture. The motion count per case is low, but the firm files heavily in the cases it chooses to push — and those cases skew toward self-represented opponents. The defining features of this firm's record are the docket itself, its procedural cadence, and the asymmetry in how heavily it files against unrepresented parties.
How they litigate (the style)
The signature is selective pressure through continuances, contempt, and modification. Three rates define them:
- 0.65 continuance markers per case (40 total; also their single most-filed motion type) — controlling the clock is their most consistent move. The timeline tends to stretch, and requests for speed tend to be contested.
- 0.42 contempt markers per case and 0.42 modification markers per case (26 each) — contempt and modification run neck-and-neck as their substantive levers. A large share of their contempt practice is post-judgment (18 of their motion filings are Motion for Contempt Post-Judgment), meaning the activity often continues long after the divorce is "final."
- 0.32 counsel-fee markers per case (20) — they reach for fee-shifting roughly a third of the time. For an under-resourced opponent, this is the relevant figure: litigating against them can carry a cost-shifting consideration.
The picture is not a blizzard of paper across the board — it's a firm that keeps the per-case motion count low (1.71) but applies sustained, post-judgment-capable activity in the cases it decides to fight.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~11.9 filings on the docket per case. The load is not evenly distributed:
- They file more against unrepresented opponents. Against a pro-se opponent: 12.7 filings/case. Against a represented opponent: 8.67/case. The party least equipped to respond carries roughly 47% more filings — a meaningful asymmetry on the side without a lawyer.
- The heaviest barrages on record (all against self-represented opponents): Andrewsikas v. Andrewsikas (HHD-FA17-6080714-S) — 58 filings; Ejchorszt v. Caswell (KNO-FA20-5108246-S) — 39; Carballo v. Granados (HHD-FA20-6134947-S) — 26 (pro se); Opare v. Witter (HHD-FA16-5043343-S) — 23 (pro se); Bracken v. Bracken (KNO-FA21-6106485-S) — 22 (pro se).
- One represented case also drew a heavy load: Hansen v. Kimball (HHB-FA23-6078204-S) — 31 filings — showing the firm will sustain volume even against counsel in some matters.
This is the core of the asymmetry: the firm's heaviest dockets cluster on self-represented opponents. A self-represented party in one of these matters fits the firm's heavier-load profile — the section below describes the procedural tools and rules that correspond to each pattern.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 40 | Controls the clock — their most-filed motion |
| Motion for Contempt Post-Judgment | 18 | Keeps activity on the docket after judgment |
| Motion for Orders Before Judgment — Pendente Lite | 7 | Sets interim terms early |
| Motion for Contempt | 6 | Shifts the matter to the other party's response, builds a record |
| Motion to Waive Statutory Time Period (Def. Failure) | 5 | Pushes default-track timing |
| Motion for Appointment of GAL | 4 | Brings a third decision-maker into custody fights |
| Motion for Order of Notice | 3 | Service / notice mechanics |
| Motion to Compel | 2 | Discovery pressure (used sparingly) |
GAL strategy
- A GAL appears in 8.1% of their cases (5 of 62), and the firm affirmatively moves for GAL appointment 4 times. This is a modest GAL footprint — they do not bring a guardian ad litem into most cases — but when custody is contested, the move is in their toolkit.
- The records do not show this firm repeatedly pairing with the same small set of guardians ad litem; the GAL usage here is best read as occasional, by rate, rather than as a fixed rotation.
Context: when a GAL is appointed, the appointment order can define scope, budget, and a reporting deadline. An unscoped GAL appointment is an open-ended cost and an open-ended variable; orders that specify those terms up front are how that variable is bounded.
The bench
They appear before Hon. Leslie Olear (10 rulings) more than any other judge, then Diana (5), Goodrow (4), Connors (3), and Nastri (3). Their ~76.7% contested-motion win rate is partly familiarity — they know these judges' preferences, calendar habits, and motion practice. Familiarity with an assigned judge's standing orders and motion practice is the kind of knowledge that narrows that experience gap.
What to expect — and your procedural options
For a focused, file-and-decide firm, the recurring patterns above each correspond to a specific procedural tool or rule. The following describes what each pattern is and what tools exist in relation to it:
- The clock. Continuances are this firm's single most-filed motion (40; 0.65/case). 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. These are the mechanisms by which the timing of a matter is contested rather than left to default.
- Contempt — especially post-judgment. Contempt is a recurring lever (26 markers; 18 post-judgment contempt filings), and it can resurface long after judgment. Contemporaneous proof of compliance with every order (payments, exchanges, communications) is the documentary record against which a contempt motion is tested. A contempt motion that is not supported by the documents is one that does not establish its factual basis.
- Modification. With 0.42 modification markers per case, orders are revisited at a meaningful rate. A current financial affidavit and clean records are the materials on which a modification question is decided; a documentation gap is what leaves that question open to dispute.
- Counsel fees. They reach for counsel fees in roughly a third of cases (0.32/case). Connecticut fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own continuances and motion volume are part of the litigation-conduct record that bears on a fee determination.
- The filing asymmetry. Their filings skew harder against pro-se opponents (12.7 vs 8.67 per case). The asymmetry tracks the gap between a self-represented party and a represented one. Responding to discovery completely and on time, calendaring every deadline, and keeping a clean paper trail are what make a self-represented party's record resemble a represented party's record on the docket.
- Volume vs merits. Their per-case motion count is low (1.71) — the record reflects a firm that selects which motions to file rather than burying a docket. A short, clean, merits-focused record is the counterpart to a selective motion practice; the substantive questions (custody, support, division) are where timing and volume have the least bearing.
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.