Opposing-Counsel Playbook: D'AGOSTO & HOWE LLC

Firm Juris No. 429818 · Connecticut · Profile built from public Connecticut Judicial Branch docket records

Limited sample (38 contested cases) — treat rates as indicative, not definitive.

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 small firm whose motion count looks modest but whose overall filing volume runs high (14.5 filings/case), with that volume falling hardest on unrepresented opponents. This firm's volume is its defining feature — the most distinctive thing the record shows is the gap between its modest motion count and its high total filing count.

How they litigate (the style)

The signature is continuance-driven pacing + GAL/custody activity + fee and discovery filings. Three markers define them:

• Continuances in roughly 3 of every 4 cases (29 cases, 0.76/case) — the single most common motion they file is a Motion for Continuance (29 of 85 motions). Pacing the clock is the recurring pattern: the timeline stretches and the matter stays open longer.
• GAL appointment activity in ~87% of cases (33 cases, 0.87/case) — the firm repeatedly puts the guardian-ad-litem machinery in motion, including affirmative motions to appoint a GAL. In custody-adjacent files, a third decision-maker is frequently invited in early.
• Counsel-fee and discovery activity in over half their cases (counsel-fee markers in 20 cases / 0.53; discovery motions in 20 cases / 0.53) — fees and discovery are routine features of these files, not last resorts. For an under-resourced opponent, this is the part of the pattern that most directly raises the cost of litigating.

Add modification activity in nearly half of cases (18 cases, 0.47) and the picture is consistent: a firm that works the procedural levers — clock, GAL, fees, discovery — rather than relying on raw motion volume.

The filing volume — and who sees the most of it

Across all cases, this firm's side puts ~14.5 filings on the docket per case. The volume is not evenly distributed:

• The volume runs higher against unrepresented opponents, not lower. Against a pro-se opponent: 16.23 filings/case. Against a represented opponent: 12.12/case. The party least equipped to respond sees the heavier paper load — roughly 34% more filings than an opponent who has a lawyer.
• The highest filing counts on record (firm filings): Apicella v. Apicella (NNH-FA20-6108025-S) — 54 filings (against a self-represented opponent); Novaes v. Boucher (UWY-FA19-5024174-S) — 42 filings (pro se); Skoronski v. Skoronski (AAN-FA25-5026542-S) — 31 filings; Austin v. Austin (FBT-FA24-6138791-S) — 31 filings (pro se); Jeffries v. Jeffries (UWY-FA09-4019908-S) — 22 filings.
• Concentrated on self-represented opponents: beyond Apicella, Novaes, and Austin above — Huq v. Pervin (DBD-FA23-5019307-S) — 21 filings (pro se).

This is the core of the volume asymmetry: a large share of the activity in these files is paper, and the unrepresented opponent is, on this data, the profile that sees the most of it. A self-represented party in a matter against this firm is, statistically, looking at the firm's heaviest-load profile — the procedural options that follow describe what the rules make available in response to that pattern.

Their motion playbook (top filings)

GAL strategy

• No case in this sample shows a GAL recorded as present on the docket (GAL-present rate: 0%), yet GAL-appointment activity appears in ~87% of cases (33 of 38), including three affirmative motions to appoint a GAL. The firm reaches for the GAL mechanism frequently even where the docket doesn't reflect a sitting GAL — a GAL proposal in one of these matters is a known tendency in the data rather than an outlier.
• No repeat GAL pairings are reportable from this sample; GAL use is described by rate only, not by individual.

Procedural context: when a GAL is proposed, the appointment order is where scope, budget, and a reporting deadline can be defined; an unscoped GAL appointment is an open-ended cost and an open-ended risk. Whether the appointment is necessary is a question the court can be asked to address on the record.

The bench

They appear most before Hon. Margarita Hartley Moore (10), then Hon. Heidi Winslow (5) and Hon. Christine Rapillo (5), followed by Kowalski (4), Boni-Vendola (2), Nieves (2), Grossman (2), and Goodrow (2). Familiarity with a recurring set of judges is part of the firm's profile. The assigned judge's standing orders and motion practice are public, and a party who reads them is working from the same baseline information.

What to expect — and your procedural options

Against a continuance-and-leverage firm, the data points to a few recurring patterns; below, each is paired with the neutral procedural tool or rule that corresponds to it. These are descriptions of how the rules work, not recommendations about any specific case.

1. The clock. Continuances are this firm's most common filing (29 of 85 motions; ~0.76/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. Each of those is a mechanism the rules make available — whether and when to use either is a case-specific decision.

1. The GAL. With GAL-appointment activity in ~87% of cases, a GAL proposal is a documented tendency in these files. The appointment order is the instrument that can define written scope, budget, and a reporting deadline, and whether the appointment is necessary is a finding the court can be asked to make. See the GAL section.

1. Fee leverage. Counsel-fee markers appear in over half their cases (~0.53/case). Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62) — meaning a party's own continuances and filing volume are part of the litigation-conduct record the statute looks to.

1. Discovery. Discovery motions appear in ~53% of cases, including 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 a court looks to when that question arises.

1. Filing asymmetry. A self-represented opponent will, on this data, likely see the heavier paper load (16.23 vs 12.12 filings/case). Matching volume is not what the rules require: a filing only calls for a response when the rules or an order require one, and unanswered over-filing remains on the filer's side of the record.

1. The merits. This firm's model leans on process — the clock, the GAL, the fee and discovery activity. The substantive questions in a family matter (custody, support, division) are decided on their merits regardless of filing volume; a short, documented, merits-focused record is the counterpart to a high-volume process record.

Methodology & limits

Computed from public CT Judicial Branch docket entries and party rosters (parties → filing-side attribution → motion/outcome tally). The decided-motion sample here is small (24 decided), so no contested-motion win-rate percentage is reported. 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.