Opposing-Counsel Playbook: Miller & Tasho LLC

Firm Juris No. 444398 · 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

Bottom line: a motion-active firm concentrated in one courthouse, with most of what it puts to a judge being granted. This firm's volume is its defining feature. The factors that distinguish cases on the record tend to be focus, documentation, and procedure.

How they litigate (the style)

The signature is discovery pressure + clock control + frequent use of contempt motions. Three numbers define them:

• 1.5 discovery motions per case (151 total) — discovery is the primary area of activity. The effect is to make the process costly and time-consuming well before the merits are reached.
• 1.26 continuances per case (127 total; Motion for Continuance is their single most-filed motion at 122) — the timeline is a recurring focus. Cases tend to stay open and stretch out.
• 0.72 contempt motions per case (73 total — across post-judgment, pendente lite, and general contempt) — contempt motions are a regular, not occasional, part of the practice. Allegations of order violations are a common feature of these cases.

Add 0.96 counsel-fee mentions per case (97 total) and the full picture emerges: active discovery, an extended timeline, a developed contempt record, and a fee question that stays open throughout the case.

The filing barrage — and who sees it most

Across all cases, the firm's side puts ~17.4 filings on the docket per case (1,754 total filings over 101 cases). The load is essentially the same whether or not the opposing party has a lawyer: 17.1 filings/case against a self-represented opponent versus 17.7/case against a represented one. In other words, being unrepresented is not associated with a lighter paper load — a self-represented party faces roughly the same volume as one with counsel.

The heaviest filing counts on record (20+ filings), several of them in cases with a self-represented opponent:

• Schimenti v. Schimenti (UWY-FA17-6035875-S) — 56 filings (opponent pro se)
• Presti v. Presti (DBD-FA22-5018907-S) — 49 filings
• Morin v. Sharek (UWY-FA18-5022962-S) — 48 filings (opponent pro se)
• Osbourne v. Osbourne (HHD-FA23-6165534-S) — 47 filings
• Cubille v. Grenier (UWY-FA21-6062583-S) — 47 filings
• Hughes v. Montiero (UWY-FA19-6047027-S) — 35 filings (opponent pro se)
• Paoletti v. Falkenham (UWY-FA23-5033745-S) — 34 filings (opponent pro se)
• Mazzella v. Lourenco (UWY-FA23-5032863-S) — 33 filings (opponent pro se)

The data indicate that a self-represented party in one of this firm's cases tends to see a heavy docket comparable to any other party's. The section below describes the procedural tools and rules that bear on that pattern.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in 15.8% of their cases (16 of 101), and the firm affirmatively moves for GAL appointment as well. In these cases GALs tend to surface as a custody-related step rather than a neutral afterthought.
• The firm repeatedly appears alongside the same guardian ad litem — one GAL recurs across the firm's cases (5 appearances). A recurring firm-and-GAL pairing is a documented pattern in the public record.

The relevant tools and rules: when a GAL is proposed, the proposed name's prior pairings with this firm are part of the public record and can be researched. A party may ask the court to appoint a GAL from outside any recurring rotation. An appointment order can define the GAL's scope, budget, and reporting deadline; an unscoped GAL appointment is an open-ended cost and an open-ended responsibility.

The bench

They appear before Hon. Christine Rapillo (50 rulings) far more than any other judge, then Grispin (21), Armata (15), Ficeto (13), and Nugent (8). Their 87% contested-motion grant rate is associated in part with familiarity — repeated appearances before the same judges, concentrated heavily in Waterbury, mean familiarity with each judge's preferences, calendar habits, and standing orders. That familiarity is something a self-represented party can also acquire by learning the assigned judge's standing orders and motion practice.

What to expect — and your procedural options

Against a firm whose practice centers on discovery and timeline activity, the public record points to a set of procedural tools and rules. Six of them, each tied to a specific pattern above:

1. Discovery. Discovery is this firm's most active area (1.5 discovery motions per case). Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented, on-time response record is what establishes a party as the compliant one. Where a discovery demand is overbroad, a targeted objection is the procedural mechanism for narrowing it. A complete compliance record also bears on the fee question described below.

1. Contempt motions. With 0.72 contempt motions per case (and 39 post-judgment contempt motions on their record), a contempt motion is a common feature of these cases. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the evidence that responds to a contempt allegation. A contempt motion that is not supported by the documents tends to fail on the record.

1. Counsel fees. With 97 counsel-fee mentions, the fee question stays open throughout these cases. In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own documentation of the opposing side's motion volume and continuances is the kind of record that bears on the litigation-conduct factor.

1. The timeline. Continuance is this firm's single most-filed motion (122), at 1.26 per case, plus 18 extensions of time. 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, which puts the burden on the moving party to justify each request.

1. Emergency custody applications. This firm has filed 13 applications for an emergency ex parte order of custody. An ex parte order is preliminary by nature, and the responding party is entitled to a prompt hearing. The hearing is the procedural point at which documentation and the full facts are considered.

1. GAL scope. A GAL appears in nearly 1 in 6 of their cases, and the same GAL recurs. The proposed name's prior pairings with this firm are public record; a party may request a GAL from outside a recurring rotation and may ask that the appointment order set a written scope, budget, and deadline. As to the broader pattern, this firm's volume is its defining feature, and the merits questions (custody, support, division) are decided on the substantive record regardless of filing volume.

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. 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.