Opposing-Counsel Playbook: Matthew J. Broder

Firm Juris No. 407384 · 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

Bottom line: a solo shop with a concentrated home district and a filing style that leans on discovery pressure and steady paper rather than a high motion count. The defining features of this profile are its focus, its reliance on the record and procedure, and the central role discovery plays in how the case unfolds.

How they litigate (the style)

The signature is discovery pressure, fee leverage, and clock control. Three patterns define them:

• Discovery is the main lever — 1.42 discovery-related motions per case (37 total, the single largest marker). Motions to compel (5) and a recurring use of PB §13-14 orders of compliance (3) show a firm where discovery is the primary battlefield. The pattern tends to make the process costly before the merits are reached.
• Fee leverage — 0.73 counsel-fee mentions per case (19 total). Fees are routinely put on the table. For a self-represented or under-resourced opponent, fee exposure is a recurring pressure point: the prospect that litigating may carry a cost.
• Clock control — 0.58 continuances per case (15 total; "Motion for Continuance" is their single most-filed motion type). A stretched timeline keeps cost and uncertainty on the other side.

Round it out with 0.62 GAL-appointment markers per case and a modest contempt/modification footprint (5 each), and the picture is a firm whose leverage sits in discovery and timeline, not in a high motion count.

The filing barrage — and who gets it worst

Across all cases, this firm's side puts ~14.3 filings on the docket per case. And the volume tilts toward the opponent least equipped to respond:

• They file more against unrepresented opponents. Against a pro-se opponent: 15.5 filings/case. Against a represented opponent: 13.29/case. A self-represented spouse faces a noticeably heavier paper load than one with a lawyer.
• The heaviest barrages on record: Barrett v. Tracy (NNH-FA23-6135114-S) — 36 filings (pro se opponent); Walker v. Walker (NNH-FA23-6131326-S) — 32 (pro se opponent); Bartlett v. Florentine (FBT-FA16-6055405-S) — 30; Mahabir v. Forty (FBT-FA24-6137886-S) — 27; Drago v. Drago (DBD-FA23-6047393-S) — 25 (pro se opponent).
• Aimed at self-represented opponents specifically: the three heaviest dockets above — Barrett (36), Walker (32), and Drago (25) — were all against parties with no attorney.

A self-represented party statistically fits the firm's heaviest-volume target profile, so the asymmetry in paper load is a pattern worth being aware of — the procedural information below describes the tools and rules that map to exactly that asymmetry.

Their motion playbook (top filings)

GAL strategy

• A GAL appears in only 7.7% of their cases (2 of 26) — below what you would see from a custody-heavy shop. But note the firm carries a 0.62 GAL-appointment marker rate, meaning the topic of GAL appointment surfaces in their filings more often than a GAL actually lands on the case.
• No reportable pattern of repeat GAL pairings emerges from this sample. A GAL proposal in this sample stands on its own merits rather than reflecting a fixed rotation.

Context: When a GAL is proposed, the proposed name is something a party can research independently in the public record. An appointment order can define scope, budget, and a reporting deadline; an unscoped GAL appointment is, by its nature, an open-ended cost and an open-ended risk.

The bench

They appear before Hon. Jane Grossman (5) more than any other judge, then Hon. Heidi Winslow (3), with Fox, Hartley Moore, Grasso Egan, Griffin, and Kenefick each at 2. The spread is wide for a small caseload — no single judge dominates. A self-represented opponent who learns the assigned judge's standing orders and motion practice closes most of the familiarity gap quickly.

What to expect — and your procedural options

Against a discovery-and-clock firm, the defining feature is that pressure concentrates on the process — discovery and timeline — rather than on the merits. Below are six observations, each paired with the procedural tools and rules that correspond to a specific pattern above. These are descriptions of how the rules work, not instructions for any particular case.

1. The discovery front. Discovery is this firm's single largest lever (1.42 discovery motions per case; motions to compel and PB §13-14 compliance orders). Responding to discovery completely and on time is what removes a non-compliance basis for sanctions. A documented, timely response — with proof of service retained — is what leaves a compliance motion with nothing to compel. Where requests are overbroad, an objection or protective motion under the discovery rules is the procedural mechanism a party may use in response.

1. The §13-14 compliance mechanism. Practice Book §13-14 orders of compliance are the rule used to force production. Such an order is directed at production that is overdue or missing; calendaring discovery deadlines, producing on schedule, and keeping proof of service are what address that mechanism. A compliance motion with nothing left to compel has no remaining basis on the docket.

1. Counsel-fee requests. Fee requests surface in roughly three of every four of this firm's cases (0.73/case), so fees being placed on the table is a likely feature. In Connecticut, fee awards turn on need and litigation conduct (C.G.S. §46b-62). A party's own record of motion and continuance volume — and which side generated the cost — is the kind of evidence that bears on a §46b-62 analysis.

1. Continuances and the timeline. Continuances are this firm's most-filed motion (15; 0.58/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. Each of these is the rule-based mechanism that maps to a firm whose leverage includes a stretched timeline.

1. The early custody front. Custody PL motions are among this firm's top filings (5), often appearing early in a case. A contemporaneous parenting record — schedules, exchanges, communications kept from the outset — is the kind of documentation that an early custody motion is met with, as opposed to a record assembled after the fact.

1. The merits. Because this is a solo shop with a moderate motion count (2.58/case), its bandwidth to litigate every front simultaneously is finite — this firm's volume is its defining feature, but volume concentrated on process is not the same as depth on the merits. A short, well-documented, merits-focused record is the counterweight that a profile like this is most sensitive to, particularly for a self-represented party carrying the heavier paper load. The substantive questions — custody, support, division — are where the case is ultimately decided.

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; here the decided-motion sample is too small to report a rate. 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.