Opposing-Counsel Playbook: Larracuente & Goulden LLC

Firm Juris No. 419147 · 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: this is a motion-aggressive firm with a high grant rate before judges it appears before regularly. The firm's volume is its defining feature; the record and procedural posture are where its filing patterns are most visible.

How they litigate (the style)

The signature is volume + discovery pressure + contempt motions. Three rates define them:

• 1.85 discovery motions per case (124 total) — the single largest marker in their history. Discovery is the firm's primary area of activity, which makes the process itself expensive and time-consuming before a case reaches the merits.
• 1.57 continuances per case (105 total) — the firm's filings extend the timeline. Combined with the discovery load, the calendar becomes a recurring feature of how these cases move.
• 1.13 contempt motions per case (76 total) plus 1.12 counsel-fee requests per case (75 total) — contempt motions appear routinely rather than as a last resort, and the firm frequently asks the court to shift fees. For an under-resourced opponent, that pairing compounds the cost of litigating: the opposing party may face both a contempt allegation and a request that fees be assessed against them.

Add 20 emergency ex parte custody applications on record and the full picture emerges: an active timeline, a heavy discovery and contempt-motion load, and live fee and custody questions that tend to remain open throughout the case.

The filing barrage — and who gets it worst

Across all cases, the firm's side puts ~21.7 filings on the docket per case (1,451 total). The volume is not evenly distributed:

• The firm files more against unrepresented opponents, not less. Against a pro-se opponent: 25.1 filings/case. Against a represented opponent: 17.8/case. The party least equipped to respond receives the heaviest paper load — a self-represented spouse faces roughly 40% more filings than one with a lawyer.
• The heaviest barrages on record: Sipko v. Sipko (FST-FA17-6031344-S) — 228 filings (the firm's all-time high, opponent pro se); Wethington v. Wethington (FBT-FA19-6091913-S) — 110 (opponent pro se); Deurquiza v. Deurquiza (FBT-FA08-4024481-S) — 91 (opponent pro se).
• Against self-represented opponents specifically: Romero Lopez v. Merali (FBT-FA23-6122084-S) — 47 filings; Bochanis v. Bochanis (FBT-FA17-6063886-S) — 41. Tens to hundreds of filings appear on dockets where the opposing party had no attorney.

This is the core of the attrition pattern: the docket volume itself is the most prominent feature. Self-represented opponents appear in the firm's heaviest-volume cases, and the section below describes what that asymmetry looks like and the procedural tools the rules make available.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in just 6% of their cases (4 of 67), even though the firm affirmatively moves for GAL appointment 10 times. GAL involvement is the exception, not the rule, in this firm's docket — though the motion appears more often where custody is contested.
• The records do not show a stable, repeated pairing with the same guardians ad litem across cases — GAL use here reads as case-specific rather than as a recurring rotation.

What the record shows: when a GAL is proposed, the proposed name's prior pairings with this firm are a matter of public record and can be researched. An appointment order can define scope, budget, and a reporting deadline; an unscoped GAL appointment leaves cost and timeline open-ended. These are descriptions of how GAL appointments are structured, not a recommendation about any specific case.

The bench

They appear before Hon. Jane Grossman (19 rulings) more than any other judge, then Lisa Grasso Egan (15), Ndidi Moses (10), Maureen Murphy (9), and Leo Diana (6). Their 76% grant rate reflects, in part, familiarity — repeated appearances before the same judges, whose preferences, calendar habits, and motion practice become known over time. A judge's standing orders are public, and familiarity with the assigned judge's standing orders is one factor that can narrow that gap.

What to expect — and your procedural options

This firm's volume is its defining feature: roughly 7 motions per case in an attrition style. The points below describe what each pattern above looks like in practice and the procedural tools the rules make available in response. They are descriptive information, not directions about any specific case.

1. The discovery activity. Discovery motions are the firm's single biggest marker (1.85/case). Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented record of timely, complete responses is what establishes a party as the compliant one. Where a discovery demand is overbroad, a motion for protective order is the procedural tool a party may use to ask the court to limit it. A complete compliance record is what a fee-shifting argument turns on.

1. The contempt motions. With 1.13 contempt motions per case (76 total), a contempt filing is a common feature of these cases. 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 is not supported by the documents is one a court can deny.

1. The fee requests. The firm frequently asks courts to shift fees (1.12 fee requests/case; 12 fee motions pendente lite). In 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 the statute addresses; the source of litigation cost is a factual question the court can consider on either side.

1. The calendar. The firm averages 1.57 continuances per case (96 motions for continuance). A continuance 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. These are the two procedural levers the rules provide on the question of timing.

1. The ex parte custody applications. The firm filed 20 emergency ex parte custody applications across its docket — front-loaded, one-sided custody filings. Connecticut's ex parte custody procedure guarantees a prompt hearing; a compliance record and a responsive affidavit are the materials a party uses to be heard at that hearing. This describes the procedure and the materials it contemplates.

1. The merits. The firm's pattern is high process volume, and it files roughly 40% more paper against self-represented opponents (25.1 vs 17.8 filings/case). A short, merits-focused record is the structural counterweight to a high-volume docket — a record organized around the substantive questions (custody, support, division) is what keeps those questions in front of the court. Filing volume and the merits are distinct dimensions of a case.

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.