Opposing-Counsel Playbook: MEEHANLAW LLC
Firm Juris No. 101342 · Connecticut · Profile built from public Connecticut Judicial Branch docket records
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
| Metric | Value | What it means |
|---|---|---|
| Contested cases (as P/D counsel) | 63 | A high-volume contested-divorce practice for a single attorney |
| Home turf | Stamford/Norwalk (FST): 28, then Bridgeport (FBT): 27, Ansonia/Milford (AAN): 3 | Lower Fairfield County is their court |
| Side they take | 35 plaintiff / 28 defendant | Files first slightly more often — tends to set the agenda |
| Motions per case | 20.0 | An extremely motion-heavy, attrition style |
| Contested-motion win rate | 77.5% (196 granted vs 57 denied) | Motions this firm files are granted more often than not where the docket records an outcome |
| Busiest judge | Hon. Donna Heller (58), then Truglia (34), Kowalski (26) | Extensive appearance history before the FST bench |
Bottom line: a motion-aggressive, single-attorney shop that files at an exceptional rate and prevails on most of what it puts in front of judges it appears before constantly. This firm's volume is its defining feature; the contrasting pattern in the record is the comparative effect of a focused, procedure-aware, record-driven approach.
How they litigate (the style)
The signature is discovery pressure + fee leverage + frequent contempt filings. Three numbers define them:
- 7.6 discovery motions per case (477 total) — motions to compel (37), commissions for deposition (36), plus a thick layer of discovery objections (79). Discovery is the firm's main battlefield. The pattern makes the process expensive and time-consuming well before a case reaches the merits.
- 5.7 counsel-fee requests per case (361 mentions; 24 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, this is the recurring pressure point: continued litigation can carry a fee-shifting risk.
- 3.4 contempt motions per case (217 total — 86 post-judgment, 54 pendente lite, 40 general) — contempt is a frequently-filed motion for this firm, not a last resort. Opponents are commonly accused of violating orders early and often.
Add 3.7 continuances per case (236) and a willingness to go ex parte (40 emergency/TRO-type events) and the full picture emerges: a long timeline, a heavy volume of discovery and contempt motions, and an active fee meter — a combination that, in the aggregate record, tends to drive cases toward settlement on terms favorable to the firm.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~51.5 filings on the docket per case — an unusually heavy paper load.
- The volume falls on represented and unrepresented opponents alike. Against a represented opponent: 52.5 filings/case. Against a pro-se opponent: 48.8/case. Either way, an opponent faces dozens of filings per case — and a self-represented spouse faces that volume without a lawyer's help.
- The heaviest filing volumes on record: Clark v. Clark (FST-FA21-6054248-S) — 256 filings (the firm's all-time high); Chase-Jenkins v. Jenkins (FST-FA17-5018340-S) — 215; Chang v. Chang (FST-FA11-4021524-S) — 176; Feher v. Feher (FBT-FA14-4048170-S) — 166.
- Against self-represented opponents specifically: Szymczak v. Dowling (FST-FA09-4029133-S) — 179 filings (pro se); Mudd v. Mudd (FST-FA20-6046100-S) — 113 (pro se); Zackson v. Zackson (FST-FA22-6056778-S) — 113 (pro se); Hall v. Hall (FST-FA14-4026845-S) — 78 (pro se); Santos v. Dos Santos (FBT-FA19-6090880-S) — 64 (pro se). Dozens-to-hundreds of filings in matters where the opponent had no attorney.
This is the core of the attrition pattern: the docket itself carries the litigation load. The volume statistics above describe what a self-represented opponent has historically encountered, and the section below describes the procedural tools and rules that exist within that context.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 198 | Controls the clock |
| Motion for Order | 193 | General-purpose pressure / agenda-setting |
| Objection to Motion | 101 | Reflexively opposes opponent's moves |
| Motion for Contempt Post-Judgment | 86 | Reopens closed cases; builds a "bad actor" record |
| Motion for Contempt Pendente Lite | 54 | Puts the opponent on defense early |
| Motion to Compel | 37 | Discovery war — opening salvo |
| Motion for Commission for Deposition | 36 | Out-of-state / third-party depositions |
| Application for Emergency Ex Parte Order of Custody | 28 | Custody pressure on no notice |
| Motion for Counsel Fees PL | 24 | Fee leverage |
| Motion for Appointment of GAL | 24 | Brings a third decision-maker into custody fights |
GAL strategy
- GAL appears in 27% of their cases (17 of 63), and the firm affirmatively moves for GAL appointment 24 times. GALs function here as a custody lever, not a neutral afterthought.
- Repeat pairings: the firm repeatedly pairs with a small set of the same guardians ad litem — one recurring GAL appears in 3 of its cases. When a firm and a GAL appear together repeatedly, that history is part of the public record.
Context: when a GAL is proposed, the proposed name's prior pairings with a firm are a matter of public docket record. The appointment order is the document that defines a GAL's scope, budget, and reporting deadline; an unscoped GAL appointment leaves those terms open-ended, which carries open-ended cost and open-ended risk.
The bench
They appear before Hon. Donna Heller (58 rulings) far more than any other judge, then Truglia (34), Kowalski (26), Diana (26), Tindill (25), Vizcarrondo (22), Hartley Moore (20), Gould (17). Their 77.5% contested-motion win rate reflects, in part, familiarity — extensive experience with each judge's preferences, calendar habits, and motion practice. In the aggregate record, the gap between a familiar firm and a new self-represented party narrows as the party learns the assigned judge's standing orders and motion practice.
What to expect — and your procedural options
A 20-motions-per-case attrition firm produces a predictable set of recurring patterns. Below, each pattern above is paired with neutral information about the procedural tools and rules that exist in Connecticut family practice for that situation.
- Discovery volume. With 7.6 discovery motions per case (compels and deposition commissions), the firm's record relies heavily on discovery. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; documenting each response creates a record of compliance. When demands appear overbroad, an objection is the procedural vehicle for raising that on the record. A clear compliance record is what bears on the fee-shifting analysis described below.
- Contempt filings. With 3.4 contempt motions per case — including 86 post-judgment contempts on record, meaning closed cases are reopened — contempt filings are common in this firm's history, including after judgment. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the kind of evidence that bears on whether a contempt motion is supported by the documents.
- Fee leverage. At 5.7 fee requests per case, the firm frequently asks courts to shift fees. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own litigation volume — here, 20 motions per case and 3.7 continuances per case — is among the conduct facts the docket records, and litigation conduct is one of the statutory factors the court weighs.
- The clock. The firm averages 3.7 continuances per case, which lengthens timelines. A continuance can be opposed on the record. A Motion to Advance is the procedural tool a party may use to ask the court to hear a matter sooner. Both are standard mechanisms for addressing case scheduling.
- Ex parte applications. With 28 applications for emergency ex parte orders of custody and 40 ex parte/TRO-type events overall, orders entered on no notice appear in the firm's history. When an ex parte order issues, a motion for a prompt hearing to dissolve or modify it is the responsive procedural vehicle; having responsive evidence assembled in advance is what makes a fast response possible.
- GAL appointments. A GAL appears in 27% of their cases, and the firm recurs to a small set of the same GALs. A proposed GAL's prior pairings are part of the public record; the appointment order is where scope, budget, and a reporting deadline are defined.
- Filing volume vs. the merits. The model centers on the process — 51.5 filings per case. The contrasting approach visible in the broader docket is a short, focused, merits-centered record: few motions, tightly documented filings, and substantive questions (custody, support, division) brought to the front. Filing volume is this firm's defining feature; a focused record is the structural alternative to matching that volume.
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. 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.