Opposing-Counsel Playbook: Fitzpatrick Santos Sousa Perugini PC

Firm Juris No. 409172 · Waterbury, CT · 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 Waterbury-centered firm with a high recorded grant rate before judges it appears before frequently, and a practice that leans on contempt and emergency-custody filings. The firm's volume is its defining feature; the record and procedure are where that volume is tested.

How they litigate (the style)

The signature is contempt + emergency custody + discovery pressure. Three numbers define them:

• 1.14 contempt motions per case (48 total — including 12 post-judgment and 8 pendente lite) — contempt is a recurring part of their practice rather than a last resort. Allegations of order violations appear early and often, and recur after judgment.
• 1.12 discovery motions per case (47 total; 6 motions to compel) — discovery is a frequent venue for their motion practice. The effect is to make the process costly and time-consuming before the merits are reached.
• 0.33 ex parte / emergency-custody applications per case (14 Applications for Emergency Ex Parte Order of Custody) — roughly one in three of their cases features a request to set the custody posture without a full hearing first. It is a fast, high-leverage opening move.

Add 0.79 continuances per case (33) and 0.36 counsel-fee requests per case (15) and the full picture emerges: an aggressive opening, sustained contempt and fee filings, and an extended timeline.

The filing barrage — and who gets it worst

Across all cases, this firm's side puts ~16.9 filings on the docket per case (708 total). The volume is not evenly distributed:

• They file more against unrepresented opponents, not less. Against a pro-se opponent: 18.1 filings/case. Against a represented opponent: 15.0/case. The party with the fewest resources to respond receives the heavier paper load — a self-represented spouse faces roughly 20% more filings than one with a lawyer.
• The heaviest barrages on record: Lorusso v. Lorusso (UWY-FA20-5026392-S) — 99 filings, opponent pro se (the firm's all-time high on record); Langlois v. Hauslaib (UWY-FA20-6053140-S) — 50 filings, opponent pro se; Dias v. Dias (UWY-FA25-5035914-S) — 45 filings; Smith v. Januszewski (HHB-FA23-5033286-S) — 40 filings.
• Against self-represented opponents specifically: Lorusso (99) and Langlois (50) above, plus Andriulaitis v. Andriulaitis (UWY-FA22-6065585-S) — 29 filings, opponent pro se; Santiago v. Burgio (UWY-FA17-5018628-S) — 23 filings, opponent pro se; Felder v. Felder (UWY-FA19-6051312-S) — 20 filings, opponent pro se. Dozens of filings directed at parties with no attorney.

This is the core of the attrition pattern: the docket itself carries the pressure. A self-represented opponent tends to fall within this firm's heavier-volume target profile — the procedural information below describes the tools and rules relevant to that asymmetry.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in only 9.5% of their cases (4 of 42) — below what one might expect for a contempt- and custody-heavy practice, though they do affirmatively move for GAL appointment (21 appointment-related markers). When a GAL does enter, it is in their higher-conflict custody cases.
• The recurring-GAL data for this firm is too thin to identify any repeat pairing, so each GAL appointment stands on its own facts rather than reflecting a fixed rotation.

What this means: when a GAL is proposed, the proposed person's prior history is a matter of public record, and an appointment order can define scope, budget, and a reporting deadline. An unscoped GAL is an open-ended cost and an open-ended risk; a scoped order is the mechanism that limits both.

The bench

They appear before Hon. Anna Ficeto (21 rulings) far more than any other judge, then Armata (8), Lawlor (8), Rapillo (6), and Nugent (6) — an overwhelmingly Waterbury (UWY) bench. Their ~78% contested-motion win rate reflects, in part, familiarity — repeated appearances before the same judges, whose preferences, calendar habits, and standing orders become known over time. That familiarity gap narrows for any party who learns the assigned judge's standing orders and motion practice, which are public.

What to expect — and your procedural options

This firm's volume is its defining feature, and the record and procedural rules are where that volume is tested. The following describes the patterns above and the procedural tools and rules that correspond to each — as information, not as a recommendation for any case:

1. The contempt pattern and the record it depends on. With 1.14 contempt motions per case — and 12 post-judgment contempts on record — contempt filings are common, including after a case is concluded. A contempt motion turns on proof of non-compliance; contemporaneous documentation of compliance with each order (payments, exchanges, communications) is what answers it. A contempt motion that is not supported by the documents tends to fail, and a failed motion can affect the moving party's credibility with a judge (Ficeto and the UWY bench) they appear before frequently.

1. The emergency ex parte pattern and the hearing it triggers. Roughly one in three of their cases features an Application for Emergency Ex Parte Order of Custody (13 on record). An ex parte order of this kind is temporary, and the law guarantees the responding party a prompt hearing. That hearing is the procedural point at which the factual basis is contested on the record; the order's status as temporary is what distinguishes it from a settled status quo.

1. The discovery pattern and what removes the non-compliance basis. They file 1.12 discovery motions per case. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; documenting each response, and meeting over-broad demands with a single targeted objection or protective motion, is the procedural counterpart. A record showing complete and timely responses is the record relevant to both the sanctions question and the fee question.

1. The fee pattern and the standard fees turn on. They file counsel-fee requests (15 on record). Connecticut fee awards turn on need and litigation conduct (C.G.S. §46b-62). Motion volume and continuances are part of the litigation-conduct record that the statute makes relevant; that record is documentable by either party.

1. The continuance pattern and the procedural tools that bear on the clock. They average 0.79 continuances per case (33 total). 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. Each continuance is something the requesting party must justify to the court.

1. The volume pattern and where the merits sit. Their practice involves a high filing volume — roughly 20% more paper against unrepresented opponents (18.1 vs 15.0 filings/case). The substantive questions in a family case (custody, support, division) are decided on the merits regardless of filing volume; a short, focused, well-documented record is the record on which those questions are reached. Filing volume and the merits are distinct, and the rules locate the decision in the merits.

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. The decided-motion sample here is small (46 decided motions across 42 cases), so the rate is indicative, not definitive. 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.