Opposing-Counsel Playbook: Goings Family Law LLC
Firm Juris No. 442237 · Connecticut · Profile built from public Connecticut Judicial Branch docket records
Limited sample (26 contested cases) — treat rates as indicative, not definitive.
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) | 26 | A smaller-volume contested-divorce practice |
| Home turf | Hartford (HHD): 12, then New Britain (HHB: 8), New London (KNO: 3) | Hartford-area courts are their base |
| Side they take | 16 plaintiff / 10 defendant | Files first more often than not — they tend to set the agenda |
| Motions per case | 7.35 | A motion-heavy, attrition style |
| Contested-motion grant rate | 57% (31 granted vs 23 denied) | When an outcome is recorded, a slim majority are granted — and a meaningful share are denied |
| Busiest judge | Hon. Daniel Klau (24), then Abery-Wetstone (12), Diana (12) | They appear in the Hartford bench repeatedly |
Bottom line: a motion-aggressive Hartford-area firm that puts heavy paper on the docket, especially in cases against unrepresented opponents. This firm's volume is its defining feature, and the modest grant rate indicates that a substantial share of its contested motions do not succeed on the merits.
How they litigate (the style)
The signature is discovery pressure + fee leverage + contempt. Three rates define them:
- 4.39 discovery motions per case (114 total) — discovery is the firm's main battlefield. The effect is to make the process expensive and time-consuming before the merits are reached.
- 2.89 counsel-fee mentions per case (75 total) — the firm routinely raises fee-shifting. For a self-represented or under-resourced opponent, the cost of litigating is a recurring theme in these filings.
- 1.58 contempt motions per case (41 total) — contempt is a frequently-filed motion here, not a last resort. Allegations of order violations tend to appear early and often.
Add 1.15 continuances per case (30 total) and the full picture emerges: an extended timeline, a high volume of discovery and contempt motions, and continued fee exposure throughout the case.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~28.2 filings on the docket per case. But the volume is not evenly distributed:
- The firm files more in cases against unrepresented opponents, not less. Against a pro-se opponent: 38.0 filings/case. Against a represented opponent: 24.6/case. 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: Khan v. Khan (HHD-FA11-4059974-S) — 140 filings, against a pro-se opponent; Reynolds v. Reynolds (NNH-FA20-6100056-S) — 83 filings; Ellison v. Ellison (KNO-FA24-6109686-S) — 64 filings.
- Against self-represented opponents specifically: Khan v. Khan (HHD-FA11-4059974-S) — 140 filings; Carrier v. Parker (HHD-FA18-5056556-S) — 35 filings; Dubreuil v. Dubreuil (KNO-FA21-5109657-S) — 33 filings; Girard v. Girard (HHB-FA20-6061459-S) — 23 filings; Getter v. Getter (HHD-FA17-6084169-S) — 20 filings. Dozens to over a hundred filings appear in cases against someone with no attorney.
This is the core of the attrition pattern: the volume of the docket itself is the defining dynamic. The data suggests self-represented opponents are statistically the most common counterparty in this firm's high-volume cases.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 28 | Controls the clock |
| Motion for Order | 20 | General-purpose pressure / agenda-setting |
| Motion for Contempt Post-Judgment | 17 | Puts the opponent on defense, builds a "bad actor" record |
| Motion in Limine | 15 | Contests what evidence the judge ever sees |
| Objection to Motion | 14 | Resists the other side's motions before they land |
| Objection | 12 | Routine resistance to the other side's filings |
| Motion for Contempt Pendente Lite | 9 | Pre-judgment contempt pressure |
| Motion for Sanctions | 6 | Escalates litigation-conduct attacks |
| Motion for Appointment of GAL | 5 | Brings a third decision-maker into custody fights |
GAL strategy
- A GAL appears in 15.4% of their cases (4 of 26), and the firm affirmatively moves for GAL appointment 5 times. The pattern is consistent with using GALs as a custody lever rather than a neutral afterthought.
- The sample does not show a single repeat guardian ad litem appearing across enough of their cases to flag a recurring pairing — so the GAL signal here is the rate of use, and any individual proposed name stands on its own record.
Context: When a GAL is proposed, the proposed name's prior pairings with this firm are part of the public record and can be researched. Appointment orders can define scope, budget, and a reporting deadline; an unscoped GAL appointment leaves cost and scope open-ended.
The bench
They appear before Hon. Daniel Klau (24 rulings) more than any other judge, then Hon. Holly Abery-Wetstone (12), Hon. Leo Diana (12), and Hon. Barry Armata (11). Familiarity with a small set of Hartford-area judges is part of the firm's profile — repeated appearances mean familiarity with each judge's preferences, calendar habits, and standing orders. A self-represented opponent's information gap on those same standing orders and motion practices is narrowest where that record is public and reviewable.
What to expect — and your procedural options
Set against a 7-plus-motions-per-case attrition firm, the following are the procedural tools and rules that correspond to each pattern described above. These are descriptions of how the procedure works, not recommendations.
- Discovery. At 4.39 discovery motions per case, discovery is the firm's main battlefield. 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 discovery that is overbroad or unduly burdensome. The record of who responded completely is what a court reviews when fee and conduct arguments are raised.
- Contempt. With 1.58 contempt motions per case (post-judgment is the firm's single biggest contempt tool at 17), contempt motions are a recurring feature of these cases. Contemporaneous proof of compliance with each order — payments, exchanges, communications — is the documentary record a court examines when a contempt motion is decided. A contempt motion that is not supported by the documents is one a court can deny.
- Counsel fees. At 2.89 fee mentions per case, the firm raises fee-shifting frequently. Under Connecticut law, 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 the statute directs a court to consider.
- Continuances and timing. Motion for Continuance is the firm's #1 filing (28). Continuances 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 moving party must justify to the court.
- High filing volume — especially in pro-se cases. The firm puts 38.0 filings/case on unrepresented opponents versus 24.6 on represented ones. Not every docket entry carries a deadline or a substantive consequence; many are routine. Identifying which filings carry a response deadline is how a party distinguishes what requires action from what does not.
- The merits. The firm's grant rate is 57% — nearly half of its contested motions that reach an outcome are denied. The substantive questions in a family case — custody, support, division of property — are decided on the merits regardless of filing volume. A focused, well-documented record is what places those questions before the court.
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.