Opposing-Counsel Playbook: Lynn Ann Pellegrino

Firm Juris No. 308903 · New Haven Judicial District · Profile built from public Connecticut Judicial Branch docket records

Limited sample (33 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 motion-active New Haven family shop that wins most of what it puts before a judge, on a home bench it appears in repeatedly. With a small sample, the defining features of the practice are volume, calendar control, and familiarity with the local bench.

How they litigate (the style)

The signature is calendar control + discovery activity + contempt-and-fee filings. Three numbers define them:

• 1.67 continuances per case (55 total; 54 motions for continuance — their single most-filed motion) — adjusting the calendar is the most consistent thing they do. Cases tend to move on their timetable.
• 1.18 discovery motions per case (39 total; 9 motions to compel) — discovery is an active front in their practice, not an afterthought. Discovery demands are common, and gaps in production tend to draw follow-up motions.
• 0.88 contempt motions and 0.88 counsel-fee touches per case (29 each) — contempt filings and fee requests tend to appear together. The recurring pattern: an alleged violation is raised, and a request follows that the opposing party bear the cost of the dispute.

Layer in 0.79 GAL-appointment motions and 0.21 ex-parte / TRO applications per case, and the picture is a firm that frequently escalates custody disputes and files for emergency relief.

The filing barrage — and where it lands heaviest

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

• They file more against unrepresented opponents. Against a pro-se opponent: 24.67 filings/case. Against a represented opponent: 20.0/case. The party least equipped to respond tends to receive the heavier paper load — a self-represented spouse faces roughly 23% more filings than one with a lawyer.
• The heaviest filing volumes on record: Zhang v. Tang (NNH-FA19-6090094-S) — 124 filings, the firm's all-time high; Nedoshytko v. Stark (NNH-FA15-4065922-S) — 50 (opponent pro se); Cardone v. Irizarry (NNH-FA18-6086496-S) — 44 (opponent pro se).
• Against self-represented opponents specifically: Nedoshytko v. Stark — 50 filings; Cardone v. Irizarry — 44; Quinn v. Quinn (NNH-FA03-0478234-S) — 41; Glennon v. Glennon (NNH-FA23-6135686-S) — 41; Crotta v. Milewski (NNH-FA08-4029795-S) — 40. Dozens of filings each, in cases where the opposing party had no attorney.

Volume is this firm's defining feature: the docket itself carries much of the litigation. The filing asymmetry between represented and self-represented opponents is the most distinctive pattern in the data.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in only 6.1% of their cases (2 of 33) — low as a share of the docket, but the firm affirmatively moves for GAL appointment 12 times. That gap means GAL appointment is a tool they reach for far more often than it lands. As a descriptive matter, a GAL motion from this firm appears to be a deliberate custody lever rather than a routine filing.
• The data does not show a recurring set of the same guardians ad litem across these cases. There is no identifiable repeat-GAL pairing to flag here.

Procedural context: when a GAL is proposed, the appointment order is where scope, budget, and reporting deadlines are typically defined; an unscoped GAL appointment leaves cost and reporting open-ended. Given this firm's 12 GAL-appointment motions against only 2 actual appointments, a GAL request is a recurring possibility even though it rarely results in an appointment.

The bench

They appear before Hon. Christopher Griffin (20 rulings) most, then Hon. Jane Grossman (17) and Hon. Erika Tindill (17), with Goodrow (13), Spader (7), Nastri (6), Kenefick (5), and Klau (3) rounding out the rotation. A 91.8% grant rate is partly familiarity — they know the New Haven bench's preferences, calendar habits, and motion practice. Each judge maintains standing orders and motion-practice rules that are part of the public record; familiarity with the assigned judge's standing orders is one factor that accounts for the firm's grant rate.

What to expect — and your procedural options

Set against a calendar-controlling, motion-active firm, the patterns above each connect to a recognized procedural tool or rule. The following describes what those tools and patterns are — not what any party should do.

1. The clock. Continuances are the firm's single most-filed motion (54; 1.67/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. In practice, an opposed continuance is one the moving party has to justify to the judge rather than receive by default.

1. The discovery front. With 1.18 discovery motions per case (9 motions to compel), discovery production is an active issue in these cases. Responding to discovery completely and on time is what removes a non-compliance basis for a motion to compel or a sanctions request, and a documented, timely response is what a clean compliance record looks like.

1. Contempt filings. At 0.88 contempt motions per case — plus 9 post-judgment contempts — contempt filings are common in this firm's practice, including after judgment. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the evidence a court weighs against a contempt allegation; a contempt motion that is not borne out by the documents tends to lose force before a judge.

1. Fee requests. With 0.88 counsel-fee touches per case, fee-shifting requests are a recurring feature. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). Motion volume and continuances are part of the litigation-conduct record the statute makes relevant; that record cuts in whatever direction the docket reflects.

1. GAL appointment scope. The firm moves for GAL appointment 12 times despite GALs landing in only 6.1% of cases. Where a GAL is proposed, the appointment order is the document that fixes written scope, budget, and a reporting deadline, which is what keeps the role from being open-ended.

1. Process vs. merits. This firm's model is built on process: heavier paper on pro-se opponents (24.67 vs 20.0 filings/case) and a 91.8% grant rate on a familiar bench. A short, clean, merits-focused record is the structural counterweight to a high-volume docket — fewer filings, each tight and documented, with the substantive questions kept at the front. This firm's volume is its defining feature, and a record organized around the merits is the dimension on which volume matters least.

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, 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.