Opposing-Counsel Playbook: Berry Law LLC
Firm Juris No. 417937 · Connecticut · Profile built from public Connecticut Judicial Branch docket records
Limited sample (33 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) | 33 | A small, single-attorney shop — but a busy one per case |
| Home turf | Hartford (HHD): 22, then New Britain (HHB): 10, New Haven (NNH): 1 | Greater Hartford is their court |
| Side they take | 22 plaintiff / 11 defendant | Files first twice as often as not — tends to set the agenda |
| Motions per case | 7.9 | A motion-heavy, attrition style |
| Contested-motion grant rate | ~73% (59 granted vs 22 denied) | Most contested motions the firm puts on the record are granted |
| Busiest judge | Hon. Susan Connors (26), then Diana (19), Armata (16) | They appear before the Hartford bench frequently |
Bottom line: a single-attorney firm that runs cases hot — heavy filing, heavy discovery, heavy fee pressure — and is granted most of what it puts in front of judges it appears before constantly. The firm's volume is its defining feature; the procedural and substantive observations below describe how that pattern shows up on the record. (Sample is small; weight the patterns, not the precise percentages.)
How they litigate (the style)
The signature is discovery pressure + fee leverage + clock control. Three numbers define them:
- 3.9 discovery motions per case (130 total) — discovery is where much of the firm's activity concentrates. The effect is to make the process expensive and time-consuming well before the merits are reached.
- 2.6 counsel-fee requests per case (87 mentions; 10 fee motions plus 8 pendente lite) — the firm routinely asks the court to make the other side pay its fees. For a self-represented or under-resourced opponent, this is a notable cost exposure: continued litigation can carry the risk of a fee-shift.
- 1.4 contempt motions per case (46 total — 23 post-judgment, 9 pendente lite, 5 general) — contempt is a frequently-filed motion for this firm rather than a last resort. Allegations of order violations appear early and often in its cases.
Add 2.3 continuances per case (75) and the full pattern emerges: a stretched timeline, a high volume of discovery and contempt motions, and ongoing fee exposure that characterize the firm's contested cases.
The filing barrage — and who sees it heaviest
Across all cases, Berry's side puts ~28.1 filings on the docket per case — a heavy load for a single-attorney firm. The volume is not evenly distributed:
- Represented opponents see the heaviest volume. Against a represented opponent: 30.3 filings/case. Against a pro-se opponent: 26.1/case. Either way, a self-represented spouse facing roughly 26 filings without a lawyer is in a deeply asymmetric situation.
- The heaviest filing volumes on record: Cyr v. Cyr (HHD-FA15-6059926-S) — 70 Berry filings (the firm's all-time high); Gomolka v. Gomolka (HHB-FA23-6082855-S) — 68 (opponent pro se); Polanski v. Polanski (HHD-FA22-6153951-S) — 57.
- Against self-represented opponents specifically: Gomolka v. Gomolka (HHB-FA23-6082855-S) — 68 Berry filings, opponent pro se; Ostapowicz v. Wisniewski (HHB-FA17-6040114-S) — 46, opponent pro se; Byroo-Johnson v. Johnson (HHD-FA13-4068580-S) — 40, opponent pro se; Gentile v. Gentile (HHD-FA16-6065820-S) — 40, opponent pro se. Dozens of filings in cases where the opposing party had no attorney.
This is the core of the attrition pattern: the docket volume itself is the firm's defining characteristic. A self-represented party in such a case can expect a paper load that is difficult to match by volume — the procedural-options section below describes the rules and tools that are relevant to that asymmetry.
Their motion playbook (top filings)
| Their move | Count | Translation |
|---|---|---|
| Motion for Continuance | 68 | Controls the clock |
| Motion for Contempt Post-Judgment | 23 | Shifts the case to defense, builds a "bad actor" record |
| Motion for Orders Before Judgment (PL) | 19 | Sets the early agenda before trial |
| Motion for Order | 16 | General-purpose pressure / agenda-setting |
| Objection to Motion | 15 | Opposes the other side's motions |
| Motion to Compel | 13 | Discovery activity — opening move |
| Motion for Counsel Fees | 10 | Fee leverage |
| Motion for Contempt PL | 9 | Pre-judgment pressure on defense |
| Motion for Counsel Fees PL | 8 | Early fee leverage |
GAL strategy
- GAL appears in 21.2% of their cases (7 of 33), and the firm affirmatively moves for GAL appointment 18 times across its history. GALs feature as a custody-related mechanism in these cases rather than a neutral afterthought.
- Repeat GAL pairings: the firm repeatedly pairs with a small set of the same guardians ad litem (one recurring GAL appears 4× across its cases). When a firm and a GAL appear together repeatedly, that recurrence is itself a documented feature of the record.
Relevant information: when a GAL is proposed, the proposed name's prior pairings with a firm are a matter of public record and can be researched. A party may ask the court to appoint a GAL from outside any recurring rotation, and may ask that the appointment order define scope, budget, and a reporting deadline up front — an unscoped GAL is an open-ended cost and an open-ended risk.
The bench
They appear before Hon. Susan Connors (26 rulings) more than any other judge, then Diana (19), Armata (16), Caron (10), Carbonneau (9). Their ~73% contested-motion grant rate is partly familiarity — repeated appearances mean exposure to each judge's preferences, calendar habits, and motion practice. For a self-represented opponent, the assigned judge's standing orders and motion practice are public and can be reviewed, which narrows that familiarity gap.
What to expect — and your procedural options
This is a near-8-motions-per-case attrition firm whose volume is its defining feature. The items below are descriptive: each pairs a pattern observed in the data with the procedural rules and tools that are generally relevant to it. None of this is advice about what to do in any specific case.
- The discovery pattern. At 3.9 discovery motions per case, motions to compel are a recurring feature. A motion to compel generally requires a non-compliance basis. Responding to discovery completely and on time is what removes a non-compliance basis for sanctions; a complete, documented response is what the record reflects when that basis is absent. The Connecticut discovery rules also provide for protective orders where requests are over-broad.
- The contempt pattern. With 1.4 contempt motions per case (23 of them post-judgment), a contempt motion is a common event in this firm's cases. A contempt finding generally turns on proof of a willful violation of a clear order; contemporaneous proof of compliance (payments, exchanges, communications) is the kind of documentation that bears on that question. A contempt motion that is not supported by the record does not result in a finding.
- The fee-request pattern. With 2.6 fee requests per case, requests to shift fees to the opposing party are routine. 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 considers under that statute.
- The continuance pattern. The firm's single most-filed motion is the continuance — 68 of them, 2.3 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. Both are standard mechanisms in CT family practice for addressing the pace of a case.
- The GAL pattern. A GAL appears in 21% of their cases and the firm moves for one 18 times; one GAL recurs 4×. A proposed GAL's prior pairings with a firm are public. A party may request a GAL from outside a recurring rotation and may ask that the appointment order specify scope, budget, and a reporting deadline.
- The volume pattern overall. The firm's model centers on process volume — ~28 filings per case. Volume is the firm's defining feature, and it is not something an opposing party can match by filing count. As a factual matter, a short, merits-focused record (custody, support, division) is a different posture from a high-volume one; which posture a given case takes is a case-specific question outside the scope of this report.
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.