Opposing-Counsel Playbook: Costa & Clark

Firm Juris No. 401576 · New London Judicial District (Norwich/KNO) · 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 focused single-district firm that runs on discovery activity and prevails on most of the motions it carries to a ruling, in front of a bench it appears before constantly. This firm's defining features are focus, the record it builds, and procedural familiarity — its volume is not its most distinctive trait.

How they litigate (the style)

The signature is discovery activity + GAL motion practice + clock management. Three rates define them:

• 1.27 discovery motions per case (99 total) — discovery is their primary area of activity. The pattern emphasizes the process before the merits, and tends to build a compliance record around the opposing party.
• 0.73 GAL-appointment events per case (57) plus 0.41 counsel-fee events per case (32) — they file for a guardian ad litem in custody disputes and routinely raise fees. For an under-resourced opponent, fees are a notable cost factor in this firm's pattern.
• 0.63 continuances per case (49) and 0.41 contempt events per case (32 — including 13 contempt PL and 7 contempt post-judgment motions) — the pattern extends the timeline and keeps the opposing party in a responsive posture, while a compliance record and fees develop in parallel.

The filing barrage — and who gets it worst

Across all cases, Costa & Clark's side puts ~13.1 filings on the docket per case (1,025 total).

• The paper load lands almost identically whether or not the opposing party has a lawyer. Against a pro-se opponent: 13.07 filings/case. Against a represented opponent: 13.21/case. There is no pro-se discount in this data — a self-represented spouse faces essentially the same volume as one with counsel, with far less capacity to answer it.
• The heaviest barrages on record: Stone v. Stone (KNO-FA20-4130913-S) — 48 filings (pro se opponent); Galipeau Jr. v. Galipeau (KNO-FA23-6108619-S) — 34; Todd v. Todd (KNO-FA18-6104327-S) — 32; Grego-Parsons v. Parsons (KNO-FA19-6104740-S) — 32 (pro se opponent).
• Cases involving self-represented opponents specifically: Stone v. Stone — 48 filings (pro se); Grego-Parsons v. Parsons — 32 (pro se); Allen v. Allen (KNO-FA23-6109271-S) — 31 (pro se); Johnson v. Johnson (KNO-FA21-6106626-S) — 30 (pro se); Megill v. Megill (KNO-FA24-6109689-S) — 30 (pro se). Several of the firm's heaviest dockets involve someone with no attorney.

For a self-represented party, the data suggests the volume is not smaller — the full filing load appears in those cases too. The section below describes what to expect from that asymmetry and the procedural options that exist.

Their motion playbook (top filings)

GAL strategy

• A GAL is recorded as present in only 2.6% of their cases (2 of 78) — but they move for GAL appointment far more often (57 GAL-appointment events; 0.73 per case). The pattern: they file for a guardian ad litem in custody matters, even though relatively few cases end with one seated.
• The available data does not support naming any recurring guardian ad litem paired with this firm, so none is identified here.

What the rules provide: when a GAL is proposed, the appointment order is the document that can define scope, budget, and a reporting deadline. An appointment order that leaves those terms open-ended leaves both cost and risk open-ended. Whether a GAL appointment is tied to the actual custody dispute is a question a party can raise on the record.

The bench

They appear before Hon. Kenneth Shluger (18 rulings) and Hon. Matthew Necci (16) far more than any other judge, then Connors (8), Newson (5), and Green (5). Their 79% grant rate on decided motions is partly familiarity — they know each judge's preferences, calendar habits, and motion practice. The assigned judge's standing orders are public, and familiarity with them is one factor that narrows a self-represented party's information gap.

What to expect — and your procedural options

A discovery-driven, single-district firm tends to operate on its own familiar ground. The patterns below correspond to specific data points above, with the procedural tools and rules that relate to each — presented as information, not as a recommendation for any case.

1. Discovery activity. This firm's highest marker rate is discovery motions (1.27/case, 99 total — 13 motions to compel). Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented, timely response record is what establishes which party is compliant. Compliance is also relevant to how fee arguments are weighed.

1. Contempt motions. With 0.41 contempt events per case (13 contempt PL, 7 post-judgment), contempt filings are part of this firm's pattern. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the evidentiary record against which a contempt motion is tested; a contempt motion that does not hold up on the documents is decided accordingly before a bench the firm appears before constantly.

1. Fee motions. Fees are raised in roughly 4 of 10 cases (32 counsel-fee events). In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own motion and continuance volume is among the cost drivers a court may consider under that standard.

1. Continuances and timing. Continuance is this firm's single most-filed motion (46) and a 0.63/case rate. Continuances can be opposed on the record. A Motion to Advance is the procedural tool a party may use to ask the court to hear a matter sooner. Either way, a requested continuance is something the requesting party may be asked to justify.

1. GAL scope. The firm files for GAL appointment far more than GALs actually appear (0.73 motions/case vs 2.6% present). When a GAL is proposed, the appointment order is where scope, budget, and a reporting deadline can be set, and whether the appointment connects to the real custody dispute is a question that can be raised.

1. The merits. This firm's pattern centers on the process — pendente lite orders, objections to opposing motions, discovery activity. A short, clean, merits-focused record is the structural counterpoint to a high-volume process. This firm's volume is its defining feature; the substantive questions (custody, support, division) are decided on their own merits regardless of filing count.

Methodology & limits

Computed from public CT Judicial Branch docket entries and party rosters (parties → filing-side attribution → motion/outcome tally). "Grant 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.