Opposing-Counsel Playbook: MEGHAN D SMITH
Firm Juris No. 431335 · New Britain (HHB) judicial district, CT · Profile built from public Connecticut Judicial Branch docket records
Limited sample (49 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) | 49 | A focused, mid-volume contested-divorce practice |
| Home turf | New Britain (HHB): 41, then Hartford (HHD: 5), with one each in Danbury, New London, Waterbury | HHB is overwhelmingly their court |
| Side they take | 33 plaintiff / 16 defendant | Files first about two-thirds of the time — tends to set the agenda |
| Motions per case | 5.1 | A motion-active practice — discovery and contempt account for much of the volume |
| Contested-motion grant rate | ~87% (66 granted vs 10 denied) | When the firm puts a contested motion on the record, it is granted in most cases with a recorded outcome |
| Busiest judge | Hon. Barry Armata (64), then Hon. Leo Diana (8), Hon. Edward Dolan (7) | The firm appears before the HHB bench frequently |
Bottom line: a focused HHB-centric firm that is granted most of what it files in front of judges it appears before regularly. This firm's volume and procedural familiarity are its defining features; focus, the record, and procedure are the dimensions on which its patterns are most visible.
How they litigate (the style)
The signature is discovery pressure + contempt + fee leverage. Three rates define them:
- 1.9 discovery motions per case (94 total) — discovery is a central area of activity for this firm. The pattern tends to make the process expensive and time-consuming before a case reaches the merits.
- 1.4 contempt motions per case (68 total — 41 contempt pendente lite, 20 post-judgment) — contempt is a frequently-filed motion for this firm, not a last resort. Accusations of order violations commonly appear early and repeatedly while a case is still pending.
- 0.59 counsel-fee requests per case (29 mentions) — the firm routinely raises fee-shifting. For a self-represented or under-resourced opponent, fee exposure is a recurring feature of how these cases unfold.
Add 1.7 continuances per case (83) and the full picture emerges: an extended timeline, sustained discovery and contempt activity, and ongoing fee requests are characteristic of this firm's docket.
The filing barrage — and who gets it worst
Across all cases, this firm's side puts ~17.7 filings on the docket per case. But the volume is not evenly distributed:
- Represented opponents draw the heaviest paper load. Against a represented opponent: 21.76 filings/case. Against a pro-se opponent: 14.64/case. The firm's filing volume is highest when there is a lawyer on the other side — but a self-represented spouse still faces nearly fifteen filings per case with no attorney to absorb them.
- The heaviest barrages on record: Putnam v. Putnam (HHB-FA20-6058011-S) — 72 filings (the firm's all-time high); Soskin v. Soskin (HHD-FA22-6151855-S) — 45; Tallis v. Discipio (HHD-FA22-6159142-S) — 44; Lizotte v. Lizotte (HHB-FA23-6080669-S) — 40; Gorneault v. Gorneault (HHB-FA21-6064271-S) — 38.
- Against self-represented opponents specifically: Syskowski v. Syskowski (HHB-FA24-6083811-S, pro se) — 35 filings; Poole v. Johnson-Pool (HHB-FA19-5026743-S, pro se) — 33; Constantino v. Constantino (HHB-FA23-6080560-S, pro se) — 32. Dozens of filings appear in cases where the opponent had no attorney.
High filing volume is the defining feature of this firm's docket. The section below describes the procedural tools and rules that correspond to each pattern above.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 81 | Affects the case timeline |
| Motion for Contempt Pendente Lite | 41 | Raises alleged order violations early; builds a conduct record |
| Motion for Contempt Post-Judgment | 20 | Continues contempt activity after the divorce is final |
| Objection to Motion | 18 | Opposes the opponent's motions; can raise the opponent's cost |
| Motion for Orders Before Judgment (PL) | 17 | Sets the pendente lite agenda |
| Motion for Order | 15 | General-purpose agenda-setting |
| Motion for Sanctions | 9 | Escalation tied to discovery or conduct disputes |
| Motion for PL Orders Including Custody | 6 | Custody positioning while the case is pending |
GAL strategy
- A GAL appears in 14.3% of their cases (7 of 49), and the firm's docket shows 30 GAL-appointment-related markers. GALs feature in this firm's custody cases.
- They repeatedly pair 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 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 research those pairings. The scope, budget, and reporting deadline of a GAL appointment are things an appointment order can define; an unscoped GAL appointment is open-ended as to both cost and duration.
The bench
They appear before Hon. Barry Armata (64 rulings) far more than any other judge, then Hon. Leo Diana (8), Hon. Edward Dolan (7), Hon. Holly Abery-Wetstone (6), with Hon. Suzanne Caron and Hon. Maria Rodriguez (5 each). Their ~87% grant rate likely reflects, in part, familiarity — repeated appearances before the same judges. A party's knowledge of an assigned judge's standing orders and motion practice is a public-records matter that tends to narrow that familiarity gap.
What to expect — and your procedural options
This firm's volume is its defining feature, and its activity concentrates in discovery and contempt. The points below describe what each pattern is and the procedural tools and rules that correspond to it — as information, not as a recommendation about any specific case.
- The discovery pattern. At 1.9 discovery motions per case, discovery is a central area of this firm's activity. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions. A complete, documented, on-time response is what a clean discovery record looks like; over-broad demands can be addressed through objections filed on the record. A record showing timely compliance is the factual answer to a non-compliance narrative and bears on fee arguments.
- The contempt pattern. With 1.4 contempt motions per case — and contempt pendente lite (41) its single most-used substantive motion — contempt is a frequently-filed motion for this firm, including while a case is still pending. Contemporaneous proof of compliance with each order (payments, exchanges, communications) is the documentary record against which a contempt allegation is measured. A contempt motion that is not supported by the documents does not succeed on its merits.
- The fee-leverage pattern. This firm averages 0.59 fee requests per case. 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 litigation-conduct record that a court may weigh under that statute.
- The continuance pattern. Motion for Continuance is this firm's most-filed motion (81; ~1.7 per case). 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. These are the two procedural levers that correspond to the firm's heavy use of continuances.
- The GAL pattern. A GAL appears in 14.3% of this firm's cases, and the firm pairs repeatedly with the same guardian. A proposed GAL's prior pairings with a firm are a matter of public record. An appointment order is the document that can define a GAL's scope, budget, and reporting deadline.
- The volume pattern overall. This firm generates ~17.7 filings per case (nearly 22 when the opponent has a lawyer); high filing volume is the model. Procedurally, the substantive questions in a family case — custody, support, division of property — are resolved on the merits regardless of filing count. A concise, documented, merits-focused record is what keeps the substantive questions in view; filing volume and merits are distinct.
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.