Opposing-Counsel Playbook: Freed Marcroft LLC
Firm Juris No. 433658 · 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) | 218 | A high-volume, statewide contested-divorce shop |
| Home turf | Hartford (HHD): 58, New Britain (HHB): 48, New Haven (NNH): 31, then New London (KNO): 28 | Central CT is their core; they range across most of the state |
| Side they take | 119 plaintiff / 99 defendant | A modest tilt toward filing first — they often set the agenda |
| Motions per case | 3.31 | A steady, motion-active practice |
| Contested-motion grant rate | 87% (205 granted vs 30 denied) | When the firm puts a contested motion on the record and a judge decides it, the motion is usually granted |
| Busiest judge | Hon. Barry Armata (35), then Connors (33), Abery-Wetstone (28), Diana (28) | They appear before a familiar Hartford-area bench |
Bottom line: an experienced, discovery-driven firm whose filings are granted in most of the contested motions a judge actually rules on. This firm's volume is its defining feature; its grant rate tracks closely with focus, the record, and procedure.
How they litigate (the style)
The signature is discovery pressure + fee leverage + clock control. Three numbers define them:
- ~2.0 discovery motions per case (431 discovery-related events) — the firm concentrates its activity on disclosure. The pattern is one in which the process becomes expensive and time-consuming well before the merits are reached.
- ~1.0 counsel-fee requests per case (215 mentions) — the firm routinely asks the court to have the other side contribute to its fees. For a self-represented or under-resourced opponent, this is a recurring cost pressure: continued litigation may carry a fee-shifting argument.
- ~1.1 continuances per case (240 total; 226 motions for continuance) — continuances are the firm's single most-filed motion. The effect is a longer timeline.
Add 0.38 contempt motions per case (82 total) and the full picture emerges: discovery activity, recurring fee arguments, frequent continuances, and contempt motions that shift the posture onto the opposing party.
The filing barrage — and who sees it most
Across all cases, Freed Marcroft's side puts ~17.2 filings on the docket per case — a substantial, sustained paper load.
The volume is distributed evenly whether or not the opposing party has a lawyer: 17.15 filings/case against a self-represented opponent versus 17.25/case against a represented one — essentially identical. In other words, the docket data shows no lighter filing load for pro se opponents; the filing intensity is comparable to what a represented party faces, but without a lawyer to absorb it.
The heaviest barrages on record:
- Alfieri v. Alfieri (HHB-FA20-6057574-S) — 78 firm filings, the firm's all-time high.
- Laffin v. Laffin (NNH-FA22-6127327-S) — 57 filings.
- Lee v. Putnam (HHB-FA18-6043394-S) — 55 filings.
- Fusco v. Fusco (NNH-FA22-6119780-S) — 51 filings.
Against self-represented opponents specifically:
- Harris v. Harris (HHD-FA14-4071424-S) — 48 firm filings, opponent pro se.
- Pitino v. Pitino (UWY-FA15-6026111-S) — 46 filings, opponent pro se.
- Bachand v. Beer (HHB-FA24-5035689-S) — 42 filings, opponent pro se.
Hundreds of filings, in some cases opposite a party with no attorney. The data indicates that self-represented opponents see the full filing load — the section below describes the procedural tools and rules relevant to that asymmetry.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 226 | Affects the timeline — their most-used filing |
| Motion for Order | 91 | General-purpose / agenda-setting |
| Motion to Compel | 44 | Discovery enforcement — a common opening filing |
| Motion for Orders Before Judgment (PL) | 42 | Sets early pendente lite terms |
| Objection to Motion | 35 | Responds to opposing motions |
| Motion for Contempt (post-judgment) | 30 | Shifts posture; builds a compliance record |
| Motion for Contempt (PL) | 23 | Same, earlier in the case |
| Motion for Exclusive Use of Premises | 16 | Addresses the home, early |
| Motion for Alimony PL | 14 | Sets support before trial |
GAL strategy
- A GAL appears in only ~6.9% of their cases (15 of 218) — below what one might expect from a high-volume custody shop. When a GAL does enter, it is the exception, not the default.
- The firm repeatedly appears alongside a small set of the same guardians ad litem (one recurring guardian appears in 3 of their cases). When a firm and a GAL appear together repeatedly, that pairing is part of the public record.
What the tools and rules are: When a GAL is proposed, the proposed name's prior pairings with a firm are a matter of public docket record. Connecticut practice allows a party to be heard on the selection of a GAL, and an appointment order can define scope, budget, and a reporting deadline. An appointment without a defined scope is an open-ended cost and an open-ended risk; a scoped order is the mechanism that addresses that.
The bench
They appear most before Hon. Barry Armata (35), then Hon. Susan Connors (33), Hon. Holly Abery-Wetstone (28), and Hon. Leo Diana (28), followed by Olear, Griffin, Caron, and Grossman. Their 87% contested-motion grant rate is associated in part with familiarity — repeated appearances before the same judges and exposure to each judge's preferences, calendar habits, and standing orders. A self-represented party who learns the assigned judge's standing orders and motion practice has access to the same published procedural information.
What to expect — and your procedural options
The firm's pattern is discovery-and-clock attrition. The following describes what to expect and the procedural tools and rules that correspond to each pattern above — as information, not as a recommendation about any specific case.
- The discovery pattern. Discovery is where the firm concentrates its activity (~2.0 discovery motions per case, 44 motions to compel). Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a documented, timely response is what the record reflects. Where a request is overbroad, a single well-supported objection or protective-order request is the procedural response Connecticut practice provides. The record of who responded completely is the factual basis a court draws on for fee and conduct arguments.
- The contempt pattern. The firm has filed 82 contempt motions across its cases (30 post-judgment, 23 pendente lite). Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the documentary record a contempt motion is tested against. A contempt motion that is not supported by the documents is one a court can deny on the record.
- The fee-leverage pattern. The firm raises counsel-fee pressure routinely (~1.0 per case, 215 mentions). Connecticut fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's motion volume and continuances are part of the litigation-conduct record a court considers under that statute, and that record is documented on the docket.
- The continuance pattern. Continuance is the firm's single most-filed motion (226). 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. Each continuance is a request the court rules on; the record reflects what was requested and what was granted.
- The pro se filing load. The firm's filing intensity against self-represented opponents (17.15/case) is comparable to what represented opponents face (17.25/case) — the docket data shows no lighter load for pro se parties. A docket-management system — a filing log, a calendar of deadlines, and template responses — is the administrative tool that corresponds to a steady filing stream.
- Volume and the merits. The 87% grant rate is associated in part with bench familiarity and in part with volume. This firm's volume is its defining feature. A short, focused, well-documented record is the procedural posture that brings the substantive questions (custody, support, division) to the front; the number of motions filed by either side does not, by itself, determine the merits.
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.