Opposing-Counsel Playbook: Reich & Truax PLLC

Firm Juris No. 439284 · 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: this is a motion-aggressive firm with a high granted-motion rate before judges it appears in front of frequently. Its volume is its defining feature.

How they litigate (the style)

The signature is discovery pressure + fee leverage + frequent continuances. Three numbers define them:

• 5.9 discovery motions per case (584 total) — motions to compel (66), protective orders (46), and discovery objections (117 marker hits). Discovery is where much of the activity sits. The pattern tends to make the process expensive and time-consuming well before a matter reaches the merits.
• 3.85 counsel-fee requests per case (381 mentions) — fees are routinely put in play. For a self-represented or under-resourced opponent, fees are a recurring feature of the docket: litigating against this firm can carry a cost-exposure dimension.
• 3.28 continuances per case (325 total; "Motion for Continuance" is their single most-filed motion at 277) — scheduling delay is a frequent feature. Combined with 2.18 contempt motions per case (216 total — 86 post-judgment, 49 pendente lite, 38 general), the aggregate picture is an attrition pattern: a long timeline, heavy discovery and contempt activity, and continuing fee exposure.

The filing barrage — and who sees it heaviest

Across all cases, Reich & Truax's side puts ~45.5 filings on the docket per case — a very heavy load. The volume is not evenly distributed:

• Represented opponents see the most paper. Against a represented opponent: 47.33 filings/case. Against a pro-se opponent: 42.09/case. Even the lighter number — what a self-represented spouse faces — is large: forty-plus filings to track and respond to.
• The heaviest filing loads on record: Stein v. Stein (FST-FA18-6035933-S) — 242 filings (the firm's all-time high); Aryeh v. Aryeh (FST-FA19-6043328-S) — 220; Knight v. Brog (FST-FA13-4026444-S) — 196; Toler v. Toler (NNH-FA19-6091954-S) — 174.
• Against self-represented opponents specifically: Hamel v. Hamel (FST-FA18-6035547-S) — 138 filings against a pro-se party; Breiner v. Breiner (FBT-FA15-6049083-S) — 125 pro-se; Ligouri v. Ligouri (FBT-FA16-6057692-S) — 96 pro-se. Hundreds of filings in matters where the opponent had no attorney.

This is the core of the attrition pattern: the docket volume itself is the defining dynamic. For a self-represented party, the per-case filing load is the central feature to understand. The section below describes what tends to follow and the procedural tools that exist.

Their motion playbook (top filings)

GAL strategy

• GAL appears in 23.2% of their cases (23 of 99) — and they affirmatively move for GAL appointment 33 times. GALs feature as a custody-related lever in this firm's practice.
• Repeat GAL pairing: the firm repeatedly pairs with a small set of the same guardians ad litem (one recurring GAL appears in 3 of their cases). When a firm and a GAL appear together repeatedly, that pairing 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. A party may ask the court to address the appointment order's scope, budget, and reporting deadline; an unscoped GAL appointment carries open-ended cost and risk. These are descriptions of how GAL appointments are structured, not a recommendation in any case.

The bench

They appear before Hon. Thomas Colin (48 rulings) more than any other judge, then Truglia (45), Heller (36), Kowalski (29), and Hartley Moore (25). Their 83% contested-motion win rate likely reflects familiarity in part — frequent appearances before the same judges. A judge's standing orders and motion practice are public; familiarity with the assigned judge's procedures is information any party can access.

What to expect — and your procedural options

Against a 15-motions-per-case attrition firm, the defining feature is volume. The following describes the patterns above and the procedural tools that exist in Connecticut family practice. These are descriptions of how the rules and tools work — not directions about what to do in any case.

1. The discovery dynamic. With 5.9 discovery motions per case, this firm's activity runs heavily on motions to compel and protective orders. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions. A Motion for Protective Order is the procedural tool a party may use to limit over-broad discovery demands. A clear record of timely, complete responses is what addresses a non-compliance narrative and bears on any fee argument.

1. The contempt dynamic. With 2.18 contempt motions per case (86 of them post-judgment), contempt activity is a frequent feature of this firm's docket. Contemporaneous documentation of compliance with court orders (payments, exchanges, communications) is the record against which a contempt motion is evaluated. A contempt motion that is not supported by the documents tends to fail on the record.

1. The fee dynamic. With 3.85 fee-related requests per case, fees are routinely placed in issue. In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own motion volume and continuances are part of the docket record that bears on the litigation-conduct factor.

1. The scheduling dynamic. Continuance is this firm's single most-filed motion (277; ~3.28 per 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, which requires the requesting party to justify the delay.

1. The objection pattern. This firm files 124 objections-to-motion plus 86 standalone objections — opposition to opposing filings is standard for them. A motion supported by the applicable rule and the record, with a request for short-calendar argument, is decided by the judge rather than on the papers alone.

1. The volume question. This firm's model centers on the process at 45.5 filings per case. A short, merits-focused record is the structural counterweight to high filing volume: fewer motions, each tied to the rule and the record, directed at the substantive questions (custody, support, division). This firm's volume is its defining feature, and a focused record is one way the substantive questions move to the front regardless of filing count.

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.