Opposing-Counsel Playbook: Conlon Amendola PLLC

Firm Juris No. 445232 · Connecticut · Profile built from public Connecticut Judicial Branch docket records

Limited sample (42 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 compact firm that files heavily per case and prevails on most decided motions before judges it sees repeatedly. The firm's distinguishing features in this sample are its focus, its use of the record, and its procedural fluency — not raw case volume.

How they litigate (the style)

The signature is discovery pressure + fee leverage + contempt. Three numbers define them:

• 2.38 discovery motions per case (100 markers; 7 motions to compel) — discovery is a primary part of how this firm litigates. The practical effect is that the process becomes expensive and time-consuming before a matter reaches the merits.
• 2.36 counsel-fee requests per case (99 markers; 7 fee motions pendente lite) — the firm routinely asks the court to make the other side pay its fees. For a self-represented or under-resourced opponent, that is the recurring pressure point: continued litigation may carry a fee-shifting exposure.
• 0.88 contempt motions per case (37 markers; 14 pendente lite, 9 post-judgment, 8 general) — contempt is a working tool in this firm's practice, not a last resort. Allegations of order violations are a common feature of these dockets.

Add 0.79 continuances per case (33) and the overall pattern is visible: an extended timeline, sustained discovery and fee activity, and ongoing cost accrual that tends to shape the posture of the case.

The filing barrage — and who gets it worst

Across all cases, this firm's side puts ~20.9 filings on the docket per case (877 total across 42 cases). The volume is not evenly distributed:

• They file more against represented opponents than against pro-se opponents. Against a represented opponent: 21.75 filings/case. Against a pro-se opponent: 15.67/case. The paper still accumulates either way — even an unrepresented spouse here faces a heavy filing load.
• The heaviest barrages on record: Lupachino v. Lupachino (UWY-FA23-5033534-S) — 65 filings (the firm's high in this sample); Haley v. Lesko (DBD-FA15-4022333-S) — 58; Filgueira v. Filgueira (UWY-FA23-6074147-S) — 54; Tannenbaum v. Tannenbaum (FST-FA21-6049690-S) — 51; Moskowitz v. Moskowitz (FST-FA21-6053734-S) — 47.
• Against self-represented opponents specifically: Wright v. Wright (DBD-FA16-6019847-S) — 30 filings against a pro-se party; Zinsser v. Merritt (FBT-FA24-6138136-S) — 26 against a pro-se party; Sargent v. Sargent (FBT-FA20-6100314-S) — 21 against a pro-se party.

In this sample, a self-represented opponent does not draw a lighter docket; the data shows the filing volume persists regardless of representation status. The section below describes the procedural options that exist in response to this pattern.

Their motion playbook (top filings)

GAL strategy

• GAL appears in 9.5% of their cases (4 of 42), but they affirmatively move for GAL appointment 8 times. They use GALs as a custody lever when one is in play, not as a routine feature of every case.
• In this sample there is no recurring guardian-ad-litem pairing — GAL appointments do not concentrate on a small repeat set. The appointment terms, rather than any particular name, are the variable that differs case to case.

What this means as information: When a GAL is proposed, the proposed name's prior pairings with this firm are a matter of public docket record. The appointment order itself is where scope, budget, and reporting deadlines are typically defined; an unscoped GAL appointment is an open-ended cost and an open-ended variable in a case.

The bench

They appear before Hon. Christine Rapillo (7) most often, then Hartley Moore (6), Fox (5), Truglia (5), and a handful with Vizcarrondo, Kowalski, and Dembo (3 each). Their high decided-motion grant rate is partly familiarity — they are accustomed to each judge's preferences and motion practice. That familiarity gap narrows as a self-represented opponent becomes acquainted with the assigned judge's standing orders.

What to expect — and your procedural options

Against a discovery-and-fee-pressure firm, the recurring dynamic is that the contest tends to play out on discovery, fees, contempt, the calendar, and filing volume. The items below describe the procedural tools and rules that exist in Connecticut family practice, mapped to each pattern above. They are descriptions of what the tools are — not recommendations about any specific case.

1. The discovery pattern. This firm runs 2.38 discovery motions per case. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented response record is what establishes which party has complied. A motion for protective order is the procedural tool a party may use when discovery demands are claimed to be excessive. The compliance record is also what a fee-shifting argument is typically built on or against.

1. The contempt pattern. With 0.88 contempt motions per case (and 14 contempt-PL motions in this sample), contempt allegations are a regular feature of these dockets. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the documentary record against which a contempt motion is measured. A contempt motion that is not supported by the documents tends to fail on the record.

1. The fee-leverage pattern. At 2.36 counsel-fee requests per case, fee-shifting is central to this firm's model. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's motion volume and continuances are part of the litigation-conduct record the court can consider when deciding who bears cost.

1. The calendar pattern. Continuance is this firm's single most-filed motion (32), ~0.79 per 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, where each one is then something the moving party has to justify.

1. The filing-volume pattern. This firm's side averages ~20.9 filings per case — and more (21.75) against represented opponents. This firm's volume is its defining feature. Each filing stands or falls on its own merits regardless of the total count; filing volume and filing outcomes are separate measures.

1. The GAL pattern. GAL appears in only 9.5% of their cases, but they move for one 8 times. When a GAL is proposed, the appointment order is where scope, budget, and reporting deadline are defined, and the proposed name's history with this firm is part of the public docket record.

Methodology & limits

Computed from public CT Judicial Branch docket entries and party rosters (parties → filing-side attribution → motion/outcome tally). "Grant rate" = Granted ÷ decided motions 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.