Opposing-Counsel Playbook: Sean Owen Kehoe
Firm Juris No. 420427 · New Britain (HHB) judicial district, CT · Profile built from public Connecticut Judicial Branch docket records
What this is. A data-driven scouting report on how this firm litigates contested family 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) | 145 | A high-volume family-docket practice |
| Home turf | New Britain (HHB): 139, then Bridgeport (2), Stamford (2), Hartford (1), Waterbury (1) | Almost everything happens in one courthouse |
| Side they take | 134 plaintiff / 11 defendant | Files first in ~92% of cases — they set the agenda and the schedule |
| Motions per case | 4.7 (682 motions) | A steady, enforcement-driven motion practice |
| Contested-motion grant rate | 82% (270 granted vs 61 denied) | When they put a contested motion to a judge, it is usually granted |
| Busiest judge | Hon. Linda Prestley (107), then Pinkus (99), Dolan (39) | They know the HHB family bench cold |
Bottom line: a single-attorney, HHB-anchored practice that prevails on most of what it files, almost always from the plaintiff's chair, and almost always against an opponent with no lawyer. This firm's volume and procedural familiarity are its defining features; the record, deadlines, and procedure are where the litigation tends to be decided.
How they litigate (the style)
The signature is post-judgment enforcement run on a fee-waivered engine. Three numbers define them:
- 1.75 contempt-related motions per case (253 markers; 44 contempt post-judgment, 20 contempt, 9 contempt pendente lite). Contempt is the firm's primary lever, not a last resort — accusations of violating an order are common, and they appear after judgment as much as before.
- 1.4 modification motions per case (203 markers; 50 modify general post-judgment, 47 modify support enforcement, 29 modify support post-judgment). This is a practice built around re-opening concluded cases and chasing support enforcement — the litigation often continues long after the divorce is "over."
- A fee-waiver intake funnel. Their single most-filed motion is Motion to Waive Entry Fee and Pay Costs of Service (157), plus 58 generic waivers. This is a high-volume, low-cost-of-entry pipeline: many cases, filed cheaply, pressed on enforcement.
Add 0.35 continuances per case (51) and a small but real ex parte / emergency-custody streak (21 markers; 10 applications for emergency ex parte order of custody) and the picture is: file first, file cheap, and use contempt and modification to maintain pressure after judgment.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~13.6 filings on the docket per case (1,977 total). But the volume is not evenly distributed:
- They file more against represented opponents than pro-se ones — but that statistic hides the real pattern. Against a represented opponent: 30.0 filings/case (only 2 such cases). Against a self-represented opponent: 13.4/case across 143 cases. The firm's entire docket is built around unrepresented opponents: 143 of 145 cases are against a pro-se party. A self-represented opponent is not an exception on this docket — that is the norm.
- The heaviest barrages on record (each against a self-represented opponent):
- Mercurio v. Mercurio — HHB-FA09-4020324-S — 91 filings (pro se)
- Muniz v. Brassard — FBT-FA12-4054667-S — 91 filings (pro se)
- Merced v. Merced — HHD-FA10-4065231-S — 78 filings (pro se)
- Ortiz v. Martir — HHB-FA10-4023563-S — 61 filings (pro se)
- Love v. Love — HHB-FA06-4010104-S — 57 filings
- Against self-represented opponents specifically, the docket also runs deep in Kavanah v. Kavanah — FBT-FA10-4057230-S — 53 filings (pro se).
This is the core of the model: cases run long and deep on enforcement, and the people on the receiving end almost never have a lawyer. The procedural information below is oriented to exactly that asymmetry.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion to Waive Entry Fee / Pay Costs of Service | 157 | The cheap-entry intake engine |
| Motion for Waiver | 58 | More fee-waiver mechanics |
| Motion for Continuance | 51 | Controls the clock |
| Motion to Modify – General Post-Judgment | 50 | Re-opens concluded cases |
| Motion to Modify Support Enforcement Services | 47 | Drives the support-enforcement machine |
| Motion for Contempt Post-Judgment | 44 | Places the opponent on defense after judgment |
| Motion to Modify – General | 29 | More modification pressure |
| Motion for Contempt | 20 | Builds a "non-compliance" record |
| Application for Emergency Ex Parte Order of Custody | 10 | The fast-custody lever |
GAL strategy
- A GAL appears in only ~2.1% of their cases (3 of 145), and the firm affirmatively moves for GAL appointment just 3 times. This is not a GAL-driven practice — guardians ad litem are rare on this docket. Custody pressure here runs through emergency ex parte applications, not through a GAL.
Context: because a GAL is the exception on this docket, an appointment, if one is ever proposed, would be unusual. When a court appoints a GAL, the appointment order can define scope, budget, and a reporting deadline; an unscoped GAL is an open-ended cost and an open-ended risk. On this firm's record, the recurring pattern is contempt-and-modification rather than GAL litigation.
The bench
They appear before Hon. Linda Prestley (107 rulings) and Hon. Barry Pinkus (99) far more than any other judge, then Dolan (39), Armata (27), and Morgan (24). Their 82% contested-motion grant rate is partly familiarity — they know the HHB family bench's preferences, calendar habits, and standing orders. A self-represented opponent who learns the assigned judge's standing orders and motion practice narrows that familiarity gap.
What to expect — and your procedural options
For an enforcement-and-modification firm, the recurring theme in the record is non-compliance. The items below describe what each pattern is, and the neutral procedural tools that exist in response — as information, not as direction for any particular case.
- Contempt is their #1 lever. With 1.75 contempt-related motions per case, a contempt motion is a frequent feature of these dockets, and it can come after judgment as well as before. Contemporaneous proof of compliance with every order — payments, exchanges, communications — is what causes a contempt motion to succeed or fail on the documents. A contempt motion that is not supported by the record is more likely to be denied.
- The post-judgment door stays open. With 1.4 modification motions per case and 50 "modify general post-judgment" filings, a case is not necessarily "over" when the decree enters. A current financial affidavit and a record of each obligation are what a post-judgment modification is litigated against; an unanswered modification can result in a default.
- The support-enforcement record matters. 47 motions to modify support enforcement and 29 to modify support post-judgment show where the pressure lands. Where support is in play, a record of each payment and each change in circumstances, kept as it happens, is what a support-enforcement motion is measured against — a documented ledger rather than a gap.
- Filing first sets the framing, not the outcome. They are the plaintiff in 134 of 145 cases. The plaintiff's pleadings frame the initial issues, but a defendant's responsive pleadings and affirmative claims are how additional issues are placed before the court. The procedural tools for raising one's own claims exist regardless of who filed first.
- Emergency ex parte applications seek fast, one-sided relief. 10 applications for emergency ex parte custody orders are on this firm's record. When an ex parte order enters, the responding party is entitled to a prompt hearing; that hearing is the procedural point at which the full two-sided record can be placed before the judge before a temporary order is extended.
- The clock and the merits. They average 0.35 continuances per case and the cases run long. 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. The firm's 82% grant rate reflects, in part, contested motions met without a developed opposing record; a complete, on-time, documented response is what an opponent puts on the other side of that figure.
This firm's volume is its defining feature, and the record shows that thoroughness, deadlines, and procedure are where these cases are most often resolved.
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.