Opposing-Counsel Playbook: Happy Even After Family Law

Firm Juris No. 433692 · 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 motion-active, discovery-driven firm whose motions are granted most of the time. The firm's defining feature is its filing volume; the patterns below describe how that volume tends to appear on the docket.

How they litigate (the style)

The signature is discovery pressure, clock control, and fee leverage. Three numbers define them:

• 1.69 discovery motions per case (297 total) — discovery is where this firm is most active. The effect of this pattern is that the process tends to become expensive and time-consuming before a case reaches the merits.
• 1.02 continuances per case (179 total; 177 motions for continuance, their single most-filed motion) — the firm is very active in managing the schedule. The timeline often extends when delay favors their client.
• 0.61 counsel-fee requests per case (107 mentions) — the firm routinely raises fees. For an under-resourced opponent, this is a recurring cost-pressure feature of the firm's practice.

Add 0.47 contempt motions per case (82 total) and 0.48 modification mentions (84) and the full picture emerges: active discovery, active schedule management, and a recurring fee question that stays live well into a case.

The filing barrage — and who sees it most

Across all cases, this firm's side puts ~18.5 filings on the docket per case (3,248 total). The volume is not evenly distributed:

• The firm files more against unrepresented opponents, not less. Against a pro-se opponent: 19.81 filings/case (69 cases). Against a represented opponent: 17.58/case (107 cases). The party least equipped to respond sees the heavier paper load.
• The heaviest filing counts on record: Parra v. Moore (FBT-FA16-5032174-S) — 113 filings (against a self-represented opponent); Barr v. Barr (FBT-FA15-6047974-S) — 76; Morisseau v. Filipczak (NNH-FA24-6146105-S) — 59 (pro se); Schenker v. Schenker (FBT-FA21-6103369-S) — 59.
• Against self-represented opponents specifically: Parra v. Moore (FBT-FA16-5032174-S) — 113 filings (pro se); Morisseau v. Filipczak (NNH-FA24-6146105-S) — 59 (pro se); Fernandez-Sainz v. Alejo (NNH-FA19-6097404-S) — 53 (pro se); Mocadlo v. Mocadlo (NNH-FA16-6064144-S) — 46 (pro se); Capecea v. Sheehan-Capecea (NNH-FA06-4022589-S) — 40 (pro se).

This is the defining feature of the firm's docket: a high volume of filings, concentrated more heavily in cases where the opposing party is self-represented. The data show that a self-represented opponent fits the profile of the cases where this firm's filing volume tends to be highest.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in about 8% of their cases (14 of 176), and the firm affirmatively moves for GAL appointment 24 times (110 GAL-appointment markers across the docket). This indicates the firm uses GAL appointments as part of its approach to custody matters.
• The data do not show a reportable pattern of the same guardians ad litem recurring across these cases, so GAL involvement here is best understood as a rate, not a known rotation.

For context: when a GAL is proposed, the proposed name's prior pairings with a firm are a matter of public docket record that can be researched. As a procedural matter, an appointment order can define the GAL's scope, budget, and reporting timeline; an unscoped appointment is, by its nature, open-ended in both cost and duration.

The bench

They appear before Hon. Jane Grossman (27) more than any other judge, then Dembo (23), Goodrow (20), Griffin (20), Armata (19), Hartley Moore (16), Tindill (14), and Kowalski (13). Their 86% contested-motion grant rate likely reflects, in part, familiarity — the firm appears regularly before these judges and is accustomed to each judge's preferences, calendar habits, and standing orders. A judge's standing orders and motion practice are public information that any party can review.

What to expect — and your procedural options

For a discovery-and-clock-intensive practice, the patterns above map onto a set of standard procedural tools. Each item below describes what a pattern is and what rule or tool corresponds to it — not what any party should do.

1. The discovery pattern. With 1.69 discovery motions per case (297 total) and 43 motions to compel, discovery is where this firm is most active. A motion to compel is the procedural tool a party uses to ask the court to require a discovery response; its premise is that the other side has not responded completely or on time. Responding to discovery completely and on time is what removes a non-compliance basis for such a motion, and a complete, timely, documented response record is what a court looks to when weighing whether a party has complied. The completeness of a party's responses is also relevant to how a court weighs the parties' litigation conduct.

1. The contempt pattern. With 82 contempt motions across the docket (26 post-judgment alone), contempt is a recurring filing in this firm's practice. A motion for contempt alleges non-compliance with an existing order; its outcome turns on the documentary record of compliance — payments, exchanges, communications. A contempt motion that is not supported by the record does not succeed, and an unsupported contempt motion can affect how a court views the moving party in a court where they appear frequently.

1. The fee pattern. The firm raises fees in roughly 0.61 instances per case. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). Because the statute considers litigation conduct, the volume of motions and continuances in a case is itself part of the record a court may consider when deciding fees.

1. The continuance pattern and the Motion to Advance. Continuances are this firm's single most-filed motion (177; ~1.02 per case). A continuance is a request to reschedule or extend a deadline, and a continuance can be opposed on the record. A Motion to Advance is the corresponding procedural tool a party may use to ask the court to hear a matter sooner. Together, these are the two procedural levers that govern the pace of a case.

1. The emergency-custody pattern. The firm has filed 16 applications for emergency ex parte orders of custody. An ex parte custody application seeks immediate relief without prior notice; by statute it is followed by a prompt hearing at which the allegations must be proven rather than assumed. That statutory hearing is the procedural point at which a responding party's evidence is heard.

1. Filing volume as the defining feature. This firm's volume — ~18.5 filings per case, and more against the unrepresented (19.81 vs 17.58) — is its single most characteristic trait. As a factual matter, the merits of a case (custody, support, division) are decided on the substantive record regardless of how many filings precede them; a short, well-documented record and a high-volume one are both resolved on the same underlying legal questions.

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.