Opposing-Counsel Playbook: Perelmutter Potash & Ginzberg P.C.
Firm Juris No. 046117 · 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) | 76 | An active, steady contested-divorce practice |
| Home turf | Bridgeport (FBT): 25, then New Haven (16), Danbury (11), Waterbury (11) | Spread across several districts, anchored in Bridgeport |
| Side they take | 41 plaintiff / 35 defendant | Slight tilt toward filing first |
| Motions per case | 5.0 | A motion-active practice — motions are a routine tool, not a rarity |
| Contested-motion grant rate | 74% (55 granted vs 19 denied) | Most contested motions this firm files end in a granted outcome |
| Busiest judge | Hon. Jane Grossman (12), then Winslow (10), Gould (10) | They appear before a familiar core bench |
Bottom line: a motion-active firm with a high grant rate before judges it appears in front of regularly, and a docket volume that runs higher against opponents without lawyers. This firm's volume is its defining feature; the rest of this page describes what that volume looks like and the procedural tools and rules that ordinarily intersect with it.
How they litigate (the style)
The signature is discovery pressure + fee leverage + clock control. Three numbers define them:
- 2.5 discovery motions per case (191 total) — including motions to compel (20), commissions for deposition (7), and a heavy stream of discovery-related extensions and objections. Discovery is a primary battlefield in this firm's practice, and the process itself tends to be cost- and time-intensive before a case reaches the merits.
- 2.1 counsel-fee touches per case (163 mentions; multiple fee motions pendente lite) — the question of who pays the lawyers is raised routinely. For a self-represented or under-resourced opponent, fee exposure is a recurring feature of litigating against this firm.
- 0.8 continuances per case (64) plus 0.5 contempt motions per case (41) — the timeline tends to stretch, and a "bad actor" narrative is kept available. Contempt is a working tool in this firm's practice, not a last resort; an opponent may be accused of violating orders.
Put together: the pattern is discovery pressure, visible fee exposure, and use of the calendar and contempt over the life of a case.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~19.5 filings on the docket per case. But the volume is not evenly distributed:
- The firm files more against unrepresented opponents, not less. Against a pro-se opponent: 26.5 filings/case (20 such cases). Against a represented opponent: 17.1/case (56 cases). The party least equipped to respond sees the heaviest paper load — a self-represented spouse faces roughly 55% more filings than one with a lawyer.
- The heaviest barrages on record: Fidel v. Fidel (FBT-FA15-6048839-S) — 107 firm filings, the all-time high; Krahel v. Czoch (FST-FA15-6024723-S) — 90 filings (opponent pro se); Fogel v. Fogel (FST-FA07-4011943-S) — 78 filings (opponent pro se).
- Against self-represented opponents specifically: Krahel v. Czoch — 90 filings; Fogel v. Fogel — 78; Krausche v. Krausche (DBD-FA19-6031680-S) — 49; Reeves v. Reeves (NNH-FA21-6118615-S) — 46; Feldman v. Feldman (FBT-FA20-6099406-S) — 42. Dozens of filings appear on the docket against parties with no attorney.
This is the core of the attrition pattern: the docket volume itself is the defining feature. The data shows that a self-represented opponent statistically sits in this firm's heavier-volume profile; the section below describes the procedural options and rules that ordinarily correspond to each pattern above.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 59 | Controls the clock |
| Motion for Order | 45 | General-purpose pressure / agenda-setting |
| Objection to Motion | 38 | Frequently contests opposing motions |
| Motion for Contempt (post-judgment) | 22 | Puts the opponent on defense, builds a "bad actor" record |
| Motion to Compel | 20 | Discovery dispute — common opening |
| Motion for Alimony Pendente Lite | 14 | Sets interim money terms early |
| Motion for Exclusive Use of Premises | 11 | Raises possession of the home up front |
| Motion for Appointment of GAL | 9 | Brings a third decision-maker into custody fights |
GAL strategy
- A GAL appears in 9.2% of their cases (7 of 76), and they affirmatively move for GAL appointment 9 times (34 GAL-appointment markers across the docket). GALs are a custody lever this firm reaches for selectively, not a neutral afterthought.
- The available data does not show a reportable pattern of the same recurring guardians paired with this firm, so GAL exposure reads as a rate to be aware of rather than a fixed roster.
Context: when a GAL is proposed, a proposed name's prior pairings with a firm are a matter of public docket record. Connecticut practice allows the appointment order to define scope, budget, and a reporting deadline; an unscoped GAL appointment is an open-ended cost and an open-ended risk. These are descriptions of how the appointment process ordinarily works, not a recommendation about any specific case.
The bench
They appear before Hon. Jane Grossman (12) more than any other judge, then Winslow (10), Gould (10), Klau (9), Ficeto (8), Truglia (7), Spader (7), and Rapillo (6). Their 74% grant rate is partly familiarity — repeated appearances tend to align a firm with each judge's preferences, calendar habits, and motion practice. A self-represented party's exposure to that familiarity gap narrows as they learn the assigned judge's standing orders, which are public.
What to expect — and your procedural options
Against a 5-motions-per-case, discovery-driven firm, the recurring patterns above each correspond to a procedural tool or rule. The items below describe what those tools and rules are and what each pattern looks like — they are information, not directions.
- The discovery dispute. With 2.5 discovery motions per case (191 total) and 20 motions to compel, discovery is this firm's main battlefield. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented, complete response is what a record of compliance looks like. A targeted objection is the procedural tool a party may use to respond to an over-broad demand.
- The contempt motion. With 41 contempt motions across their cases (22 post-judgment), this is a frequently-filed motion in the firm's practice. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the evidentiary record against which a contempt motion is decided. A contempt motion that is not supported by the documents tends to fail, and the outcome appears on a docket the firm appears in front of regularly.
- The fee question. With 163 counsel-fee touches across the docket, the "who pays the lawyers" question is a recurring feature. Under Connecticut law, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A firm's own motion volume and continuances are part of the litigation-conduct record that a court may consider on a fee question.
- The calendar. This firm files 59 continuances (0.8 per case). A continuance is a request to move a matter later, and it 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 ordinary calendar-management mechanisms available to either side.
- The heavier paper load for self-represented parties. Self-represented opponents see 26.5 filings/case versus 17.1 against represented parties — and the heaviest dockets on record (90, 78, 49, 46, 42 filings) were all in cases against unrepresented spouses. A tracking system that logs every filing, every deadline, and every response is the organizational tool that ordinarily corresponds to a high-volume docket.
- The GAL appointment. GALs appear in 9.2% of their cases, more often when custody is the central issue. A proposed GAL's prior pairings are part of the public docket record, and Connecticut practice allows the appointment order to specify scope, budget, and a reporting deadline.
- Process volume versus the merits. This firm's edge is process — discovery, fees, and the calendar — and its volume is its defining feature. A short, merits-focused record is the structural alternative: the substantive questions in a family case (custody, support, division) are decided on their own record regardless of how many procedural filings precede them. This is an observation about how the two kinds of filings relate, not advice about what to file.
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 (74 decided motions); 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.