Opposing-Counsel Playbook: GRABERROBERTS LLC

Firm Juris No. 439301 · Lower Fairfield County, CT · Profile built from public Connecticut Judicial Branch docket records

This is general information about public litigation patterns — not legal advice, and not a recommendation about what to do in any specific case.

Limited sample (25 contested cases) — treat rates as indicative, not definitive.

What this is. A data-driven profile of 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.

Snapshot

Bottom line: a focused, motion-active firm that prevails on most of what it puts in front of a judge it appears before constantly. This firm's defining features are focus, attention to the record, and procedural activity rather than sheer volume.

How they litigate (the style)

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

• 2.84 discovery motions per case (71 total) — discovery is where much of their activity concentrates. Common filings include motions to compel, protective orders, and extension-of-time disputes over discovery. The practical effect is that the process itself becomes substantial before the merits are reached.
• 2.88 counsel-fee mentions per case (72 total) — they routinely put fees in play, asking the court to shift cost to the other side. For a self-represented or under-resourced opponent, this is a notable feature: cost can become part of the litigation calculus.
• 1.08 contempt motions per case (27 total — post-judgment, pendente lite, and general) — contempt appears as a recurring filing rather than a last resort. Allegations of order violations are a common feature of their cases.

Add 1.0 continuance per case (25) and the picture is complete: the pace of the case, the discovery and fee activity, and the contempt filings together describe a practice oriented toward sustained procedural pressure.

The filing volume — and where it concentrates

Across all cases, this firm's side puts ~22.2 filings on the docket per case. The volume is not evenly distributed:

• Filing volume is higher against unrepresented opponents. Against a pro-se opponent: 34.67 filings/case. Against a represented opponent: 18.26/case. The party without counsel sees nearly double the paper load — a self-represented spouse faces almost twice as many filings as one with a lawyer.
• The heaviest volume on record: Powers v. Hiranandani (FST-FA14-4028425-S) — 103 filings (the firm's all-time high, against a pro se opponent); Raveret v. Neuhaus (FST-FA21-6053925-S) — 46 filings (also pro se); Napolitano v. Curran (FST-FA16-6029596-S) — 39; Gilson v. Gilson (FST-FA16-6029854-S) — 37; Ache v. Ache (FST-FA19-6043114-S) — 33.
• Against self-represented opponents specifically: beyond the two above, Karsch v. Karsch (FST-FA19-6040752-S) — 33 filings, all involving a party with no attorney.

This is the core of the firm's high-volume pattern: docket activity is heaviest in cases where the opponent is unrepresented. A self-represented party is, statistically, the profile that sees the largest filing load in this firm's history.

Their motion patterns (top filings)

GAL strategy

• A GAL appears in only 8% of their cases (2 of 25) — modest by contested-firm standards — but they affirmatively move for GAL appointment 5 times. Where custody is contested, a motion to bring in a third decision-maker is a recognized possibility.
• No recurring guardian-ad-litem pairing is reportable from this sample; GAL involvement is best understood by rate, not by any named rotation.

What the rules provide: when a GAL is proposed, the proposed name's prior pairings with this and other firms are matters of public record. An appointment order can define scope, budget, and a reporting deadline; an unscoped GAL appointment leaves cost and duration open-ended.

The bench

They appear before Hon. Donna Heller (15 rulings) far more than any other judge — then Moukawsher (2), with Frankel, Stewart, Truglia, Hartley Moore, Tindill, and Colin each appearing once. Their win rate is partly a function of familiarity: repeated appearances build knowledge of a judge's preferences, calendar habits, and standing orders. That familiarity gap narrows as a party learns the assigned judge's standing orders and motion practice, which are publicly available.

What to expect — and your procedural options

The patterns above point to a discovery-and-contempt-oriented practice. Below, each pattern is paired with the procedural tools and rules that relate to it — described as information, not as a recommendation about any specific case.

1. Discovery activity. At 2.84 discovery motions per case, discovery is where this firm is most active. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; documenting responses creates a record of compliance. A protective order is the procedural tool a party may use to limit or object to disclosure demands that are overbroad. Completeness and timeliness of discovery responses are what neutralize a non-compliance narrative and bear on the fee question.

1. Contempt filings. With ~1.08 contempt motions per case (15 of them post-judgment), contempt is a recurring feature. Contemporaneous proof of compliance with each order — payments, exchanges, communications — is the kind of record on which a contempt motion is decided. A contempt motion that is not supported by the documents is one that, on the record, does not succeed.

1. Counsel-fee activity. With 72 counsel-fee mentions, fees are routinely placed in play. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own motion volume and continuance practice are part of the litigation-conduct record that the statute makes relevant to fees.

1. Case timing. They average one continuance per case (21 continuance motions). 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, and the court may require the moving party to justify a continuance.

1. Filing asymmetry. A pro-se opponent sees 34.67 filings/case versus 18.26 for a represented one — nearly double. A self-represented party is, by these numbers, the profile that faces the largest filing load. Filings carry differing deadlines and stakes; not every docket entry calls for the same response.

1. The merits. With 76% of their decided motions granted (16 of 21 — a small sample), the firm's measurable edge is in procedure before a familiar bench. The substantive questions in a family case — custody, support, division of assets — are decided on their own record. This firm's volume is its defining feature; the merits of any case are a separate matter from how many filings appear on the docket.

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, so this rate rests on a small decided-motion sample. 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.