Opposing-Counsel Playbook: Jonathan Edward Harding
Firm Juris No. 434270 · New Britain (HHB) judicial district, CT · Profile built from public Connecticut Judicial Branch docket records
What this is. A data-driven scouting report on how this firm litigates contested family 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 |
|---|---|---|
| Cases (as P/D counsel) | 434 | A very high-volume family-docket practice |
| Home turf | New Britain (HHB): 422, then Hartford (7), Waterbury (4), New Haven (1) | The New Britain courthouse is essentially their home court |
| Side they take | 432 plaintiff / 2 defendant | They almost always move first — they set the agenda and the calendar |
| Motions per case | 0.41 | Low per-case motion volume; this is a high-throughput, low-friction practice, not a motion-war shop |
| Contested-motion grant rate | 82% (90 granted vs 20 denied) | When they put a contested motion in front of a judge, it usually carries |
| Busiest judge | Hon. Lisa Morgan (15), then Carbonneau (13), Armata (11) | A familiar bench they appear before constantly |
Bottom line: a high-volume, plaintiff-side family practice that moves a large number of cases through one courthouse efficiently and wins most of the contested motions it files. This firm's volume is its defining feature; the record, the applicable procedure, and the specific motion before the court are where individual cases are decided.
How they litigate (the style)
The signature is high throughput, plaintiff-side, support-and-enforcement driven. Three patterns define them:
- They file first, almost always. 432 of 434 cases are on the plaintiff side. They initiate, they frame the case, and they control the opening posture. In nearly every case the opposing party is responding to their filing, not the other way around.
- Lean motion practice, heavy on enforcement. At 0.41 motions per case this is not a bury-you-in-paper firm. The motions they do file cluster around enforcement and process: their top markers are contempt (67 across the docket, 0.15/case), modification (39), and continuance (33). The pressure comes from contempt and support-enforcement, not from a discovery war — discovery motions barely register (1 on the entire docket).
- Fee-waiver volume signals the client base. Their single most common motion type is the Motion to Waive Entry Fee and Pay Costs of Service (55), plus 7 more general fee-waiver motions. That is the fingerprint of a high-volume, often state-assisted support/enforcement practice — many cases moving quickly, many filed in forma pauperis.
In short: this is an efficient enforcement-and-support practice, not a scorched-earth litigation boutique. The pattern that matters most to an opposing party is a contempt or support-enforcement motion supported by the record, not a high volume of filings.
The filing volume — and who sees it most
Across all cases, this firm's side puts ~3.16 filings on the docket per case — a light footprint per case, consistent with a high-throughput model.
That number is essentially the same whether the opponent has a lawyer or not: 3.16 filings/case against a self-represented opponent versus 3.0/case against a represented one. The firm does not ramp up paper volume specifically against the unrepresented. Note the raw exposure: 431 of 434 opponents on this docket were self-represented. Self-represented opponents are not a special target so much as the entire field — an unrepresented party here is the typical adversary, and the procedural information below is framed for exactly that common posture.
The heaviest individual cases on record (firm-side filings):
- Ferraro v. Ferraro, HHB-FA14-4035087-S — 44 filings (opponent pro se)
- Hicks v. Hicks, HHB-FA05-4005595-S — 26 filings (opponent pro se)
- McDonald v. Santiago, HHB-FA11-4027238-S — 25 filings (opponent pro se)
- Gourneault v. Felix, HHB-FA14-4035791-S — 24 filings (opponent pro se)
Each of these heaviest files was against a self-represented opponent. They are the exception, not the rule — but they show what a contested, drawn-out enforcement matter with this firm looks like.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion to Waive Entry Fee and Pay Costs of Service | 55 | High-volume / often fee-waived intake |
| Motion for Continuance | 33 | Controls the clock |
| Motion to Modify Support Enforcement Services | 12 | Support-enforcement machinery |
| Motion for Contempt Post-Judgment | 10 | Enforces existing orders; builds a non-compliance record |
| Motion for Waiver | 7 | More fee-waiver volume |
| Application for Writ of Habeas Corpus | 5 | Used to compel a party's appearance/production |
| Motion for Order | 5 | General-purpose pressure / agenda-setting |
| Motion to Modify – General | 4 | Adjusts existing orders |
| Motion to Cite Additional Party | 4 | Brings new parties into the case |
GAL strategy
A guardian ad litem appears in only 0.9% of this firm's cases (4 of 434), and the firm moves for GAL appointment just once on the entire docket. GALs are not part of this firm's standard playbook. Because there is no recurring guardian-pairing pattern in the data, a GAL proposal in a matter involving this firm is statistically unusual relative to its docket history.
Context: GAL appointment orders commonly address scope, budget, and reporting timelines; an appointment order that leaves these undefined leaves the cost and the role open-ended. That is a feature of GAL appointments generally, not specific to this firm.
The bench
They appear before Hon. Lisa Morgan (15 rulings) most often, then Carbonneau (13), Armata (11), Dolan (10), Connors (10), and Abery-Wetstone (9) — a tight cluster of New Britain-district judges. Their 82% contested-motion grant rate is partly familiarity: they know these judges' calendars, standing orders, and motion habits. That familiarity gap narrows for any party — represented or not — who becomes acquainted with the assigned judge's standing orders and motion practice.
What to expect — and your procedural options
Against a high-throughput, plaintiff-side enforcement firm, the recurring patterns are concentrated in a few specific motion types. The following describes what each pattern is and which procedural tools and rules relate to it. Each item is tied to a specific pattern above and is descriptive, not a recommendation.
- The calendar is set early, and continuances shape timing. This firm files first in 432 of 434 cases and uses continuances (33) to manage timing. 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. Deadlines generally run from the date of service.
- Contempt is the most-used substantive marker. Contempt is this firm's most-used substantive marker (67 across the docket; post-judgment contempt is their #4 motion type), so it is a common move in contested matters. The factual basis for a contempt motion is compliance with the underlying order; contemporaneous proof of compliance — payments, exchanges, communications — is what addresses a contempt motion on the documents.
- Support and enforcement run through modification motions. This firm's machinery runs through support-enforcement modifications (12) and support-enforcement motions. A Motion to Modify is the procedural vehicle a party uses to adjust an existing support order when finances change; it is filed independently and does not require waiting for an enforcement motion to be filed first.
- The 82% grant rate sits on a modest sample. That rate is computed on a modest decided sample (110 decided motions; 90 granted, 20 denied) and is partly judge familiarity. 20 of their contested motions were denied. A written objection and appearance put each motion to its proof on the record; the grant rate describes aggregate history, not the outcome of any particular contested motion.
- Fee waivers are available to any party. This firm's most common motion is a fee/service-cost waiver (55) — the same tool is available to any party. The fee-waiver application (JD-FM-75 / Application for Waiver of Fees) is the form a party may use when filing or service costs are a barrier.
- This firm's volume is its defining feature. It moves many cases efficiently through one courthouse. The contrast that the record shows is between high case volume on the firm's side and the merits of the specific issues — support, custody, modification — that decide any one case. A short, complete, documented record on those issues is what keeps a matter focused on the substantive question.
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.