Opposing-Counsel Playbook: Gans & Gans
Firm Juris No. 409207 · Connecticut · Profile built from public Connecticut Judicial Branch docket records
Limited sample (37 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
| Metric | Value | What it means |
|---|---|---|
| Contested cases (as P/D counsel) | 37 | A small but active contested-family practice |
| Home turf | Bridgeport (FBT): 29, then Danbury (3), Stamford (2), New Haven (2), Torrington (1) | The Bridgeport JD is overwhelmingly their court |
| Side they take | 26 plaintiff / 11 defendant | Files first about 70% of the time — tends to set the agenda |
| Motions per case | 2.41 | A moderate, targeted motion rate — not a paper-blizzard shop |
| Contested-motion grant rate | 78% (21 granted / 27 decided) | When they take a motion to decision, it usually lands — but see the caveat below |
| Busiest judge | Hon. Margarita Hartley Moore (9), then Grossman (5), Moses (5) | They appear before the Bridgeport bench repeatedly |
Bottom line: a Bridgeport-centered firm that files first, keeps motion volume disciplined, and has most of the motions it brings to decision granted. The defining features of their record are focus, a developed paper trail, and procedural familiarity — and a tendency to file most heavily against under-resourced opponents.
Caveat on the grant rate: only 27 motions in this sample reached a recorded decision. That is a small set — read 78% as a directional signal, not a reliable batting average.
How they litigate (the style)
The signature is fee leverage + discovery pressure + a steady drumbeat of contempt. Three marker rates define them:
- ~1.0 counsel-fee request per case (38 mentions) — fees come up in roughly every case. The firm routinely positions the court to consider making the other side pay. In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62), so this marker reflects how often that question is put before the court.
- ~0.8 discovery motions per case (30 total) — discovery is a real battleground for them. Motions to compel and broad demands are common features of their dockets, and discovery disputes can make the process costly before a case reaches the merits.
- ~0.57 contempt motions per case (21 total) and ~0.57 continuances per case (21 total) — contempt appears as a regular tool, not a last resort, and continuances are a frequent feature of how their cases move through the calendar. Allegations of order violations and a stretched timeline are both common in this sample.
Add a GAL-appointment marker in about half their cases (0.54/case) and the picture is clear: fees, discovery pressure, a developing "non-compliance" record through contempt, and frequent reference to a third decision-maker in custody fights are the recurring elements of their practice.
The filing volume — and who sees the most of it
Across all cases, Gans & Gans's side puts ~14.1 filings on the docket per case — a meaningful paper load, even if the motion rate is modest (most filings are not motions).
The volume tilts toward unrepresented opponents:
- The firm files more against unrepresented opponents. Against a pro-se opponent: 14.63 filings/case. Against a represented opponent: 13.56/case. The party least equipped to respond is, on average, the one that sees the heavier paper load.
- The heaviest dockets on record: Carter v. Heron (FBT-FA20-6096370-S) — 67 filings (the firm's high in this sample, opponent pro se); Oliveira v. Oliveira (FBT-FA16-6058709-S) — 24 filings (opponent pro se); Smith v. Smith (FBT-FA23-6128309-S) — 22 filings; Wood v. Wood (FBT-FA24-5055099-S) — 22 filings (opponent pro se); Manick-Highsmith v. Highsmith (NNH-FA23-6138804-S) — 21 filings.
- Against self-represented opponents specifically: beyond Carter, Oliveira, and Wood above — Farmer v. Farmer (FBT-FA24-6130977-S) — 20 filings, opponent pro se. The heaviest filing volumes in this sample fall on parties without an attorney.
A self-represented party in one of this firm's cases statistically fits the heavier-filing profile described above — that asymmetry is the recurring pattern the sections below describe.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 20 | Affects the pace of the calendar |
| Motion for Order | 17 | General-purpose / agenda-setting |
| Motion for Contempt | 7 | Shifts the other party to defense, builds a compliance record |
| Motion for Contempt Pendente Lite | 5 | Same posture, pre-judgment |
| Motion for Custody of Minor Children PL | 4 | Opens a custody front early |
| Motion for Contempt Post-Judgment | 4 | Keeps compliance at issue after judgment |
| Motion to Compel | 4 | Discovery dispute |
| Application for Emergency Ex Parte Order of Custody | 3 | High-stakes, fast-moving custody filing |
GAL strategy
- A GAL is actually present in only ~5.4% of their cases (2 of 37) — low — yet they carry a GAL-appointment marker in roughly half their cases (0.54/case, 20 mentions). The gap suggests the firm frequently raises or moves for a GAL as a custody-related step even where one is not ultimately appointed. A GAL motion in this firm's cases is, statistically, more often a procedural lever than a precursor to an actual appointment.
- No reportable pattern of the same recurring guardians ad litem appears in this sample, so GAL use here is best understood by rate rather than by any repeat-pairing claim.
Context on GAL appointments: when a GAL is appointed, the appointment order can define scope, budget, and a reporting deadline up front; an unscoped GAL is an open-ended cost and an open-ended risk. The party opposing a GAL request can ask the court to address why a GAL is needed. These are the procedural questions a court typically considers around a GAL appointment.
The bench
They appear before Hon. Margarita Hartley Moore (9 rulings) more than any other judge, then Grossman (5), Moses (5), Truglia (3), and Kowalski (3) — heavily concentrated in the Bridgeport JD. Familiarity with a small set of judges is part of any local firm's edge. A judge's standing orders and motion-practice preferences are part of the public record and are the same for every party who appears before that judge.
What to expect — and your procedural options
This firm's record centers on a Bridgeport-based, fee-and-contempt-heavy practice. The patterns above each correspond to specific Connecticut procedural rules and tools. The following describes what each pattern is and the procedural mechanisms that exist around it — as information, not as a recommendation about any case.
- The fee leverage. Fees surface in nearly every one of their cases (~1.0/case). In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62) — which means a party's own motion volume and continuances can themselves bear on a fee analysis. The record of who drove litigation cost is part of what a court weighs.
- The discovery battleground. With ~0.8 discovery motions per case, discovery disputes are common. Responding to discovery completely and on time is what removes a non-compliance basis for a motion to compel or for sanctions. Where a demand is overbroad, a targeted objection or a protective order is the procedural tool that addresses it. A complete, documented response record is what establishes a party's compliance.
- The contempt motions. Contempt motions run ~0.57/case (21 total, including pendente lite and post-judgment). A contempt finding requires proof of a clear order and a willful violation; contemporaneous proof of compliance with each order (payments, exchanges, communications) is the evidence that bears directly on that question. A contempt motion that is not supported by the documents is, on the record, unsupported.
- The calendar pace. Continuance is their single most-filed motion (20) and runs ~0.57/case. A continuance can be opposed on the record, and a Motion to Advance is the procedural tool a party may use to ask the court to hear a matter sooner. Both are standard mechanisms for addressing the pace of a case.
- The custody filings. Their motion mix includes custody PL motions (4) and emergency ex parte custody applications (3). When an ex parte custody order issues, Connecticut procedure provides for a prompt follow-up hearing — ex parte relief is, by design, meant to be tested quickly at a hearing where the full context can be placed on the record.
- The filing-volume asymmetry. The firm files more against unrepresented opponents (14.63 vs 13.56 filings/case), and their heaviest dockets — Carter v. Heron (67), Wood v. Wood (22), Farmer v. Farmer (20) — were largely against self-represented parties. This firm's volume is its defining feature in this sample. A focused, well-documented record — and surfacing the substantive questions (custody, support, division) — is what those numbers stand in contrast to.
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, and the decided-motion sample here is small. 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.