Brandy E. Raulerson, Appellant,
Jose P. Font, Appellee.
final until disposition of timely filed motion for rehearing.
Appeal from a non-final order from the Circuit Court for
Miami-Dade County, Lower Tribunal No. 17-18397 Luise Krieger
Barnard Law Offices, and Andrew C. Barnard and Garrett
William Haakon Clifford, for appellant.
& Nelson, and Jose P. Font and Frantz C. Nelson (Fort
Lauderdale), for appellee.
SUAREZ, SALTER and FERNANDEZ, JJ.
attorney Brandy E. Raulerson ("Ms. Raulerson")
appeals an order dismissing her petition for an injunction
against stalking as against the appellee, Florida-licensed
attorney Jose P. Font ("Mr. Font"). We affirm the
order, concluding, as the trial court did, that the sworn
allegations in the petition (a) primarily involve conduct
outside the definitions and boundaries of the applicable
statutes,  and (b) present certain issues best
addressed under the disciplinary framework established by the
Rules Regulating The Florida Bar.
Raulerson is an associate attorney employed by a law firm
(Barnard Law Offices, L.P., "BLO"), which regularly
represents insured homeowners and other parties with
insurance claims, including bad faith claims. The senior and
"name" partner at BLO is Andrew C. Barnard
("Mr. Barnard"). Mr. Barnard was designated as Ms.
Raulerson's attorney for purposes of the stalking case,
and he also represents her in this appeal. The petition
includes allegations regarding conduct witnessed by Mr.
Barnard and statements heard by him, in each case relating to
lawsuits and conduct in a courtroom or courthouse.
respondent, Mr. Font, is identified in the petition as the
managing partner of a law firm, "Font & Nelson,
LLC," in Fort Lauderdale. Mr. Font's law firm
regularly represents insurers, and Mr. Font has expressed a
particular interest in identifying fraudulent insurance
claims for prosecution under the applicable criminal
statutes. The petition alleges that Mr. Font, among other
wrongful acts: "threatened, harassed, stalked,
cyberstalked, or abused" Ms. Raulerson; "threatened
to harm [Ms. Raulerson] and individuals closely associated
with [Ms. Raulerson];" "repeatedly harassed and
threatened [Ms. Raulerson] and her co workers and her
employer by forcing her to appear at court hearings having
nothing to do with her, and then threatening her with
criminal actions, going so far as to publish a false
affidavit against her which he suborned from a prior
client;" and repeatedly published the affidavit "in
all cases involving [BLO] as well as other cases where [BLO]
has no involvement whatsoever."
eleven-page petition continues, the underlying details
(dates, times, locations, specific threats - verbal,
nonverbal, or implied) are sparse, but include these
• Mr. Font is alleged to have made "verbal threats
to [Ms. Raulerson] that he will cause her to lose her bar
license and livelihood and reputation."
• Mr. Font is alleged to have harassed Ms. Raulerson
because of her "rejection of his crude sexual
advances." This was alleged to have begun in January
2016, the first encounter between the two attorneys, at an
examination under oath of an insured conducted by Mr. Font
and attended by Ms. Raulerson and another attorney from BLO.
Mr. Font allegedly asked the other BLO attorney, within the
hearing of Ms. Raulerson, if he was having sexual relations
with Ms. Raulerson. The petition alleges that this was done
"with the obvious intent or objective that Mr. Font
himself wanted to [have sexual relations with
• Following this incident, Ms. Raulerson was upset and
complained to BLO and Mr. Barnard. Mr. Barnard
"contacted Mr. Font and expressed his concern to Mr.
Font about such abuse from an attorney against a young
associate. Mr. Font told Mr. Barnard to 'f**k
• At some later time, Mr. Font allegedly told Ms.
Raulerson "he was having her watched by means of remote
• These circumstances caused Ms. Raulerson "extreme
mental anguish resulting in physical illness (hives,
vomiting, lost sleep, loss of enjoyment of life,
disparagement of reputation)." Mr. Font's threats
have caused Ms. Raulerson's level of discomfort to rise
"from high anxiety to revulsion against Mr. Font to the
point where she has applied for and obtained a concealed
ninety percent of the allegations in the petition, however,
are related to unprofessional conduct in litigation by Mr.
Font-issuing subpoenae to require Ms. Raulerson to appear at
insurance case trials, even when she was not involved; filing
an allegedly-defamatory affidavit in over a dozen insurance
cases; becoming "unhinged" after BLO "obtained
a money judgment against him individually for $8, 332.50 for
discovery abuses" in May 2017; making threats while
"hiding behind 'judicial privilege;'"
wasting Ms. Raulerson's time in an effort to have her
fired, "obviously for 'revenge' and to make the
case as expensive as possible for [the plaintiff in a given
injunction for protection sought in the petition asked that
Mr. Font be prohibited from "going to or within 500 feet
of any place [Ms. Raulerson] lives, or to any specified place
regularly frequented by [her] and any named family members or
individuals closely associated with [her.]" Those
individual co-workers closely associated with Ms. Raulerson
were alleged to include Mr. Barnard, any member of his
family, or any associates or employees of BLO.
petition also sought injunction provisions prohibiting Mr.
Font from going to or within 500 feet of the BLO law office,
going to or within 100 feet of Ms. Raulerson's motor
vehicle "whether or not that vehicle is occupied,"
and contacting Ms. Raulerson by telephone, mail, email, in
writing, through another person, "or in any other
keeping with the statutory procedure in section 784.0485, a
temporary injunction for protection against stalking violence
was issued on the day the petition was filed, and the matter
was scheduled for an evidentiary hearing and consideration of
a final judgment of injunction some fifteen days later. Mr.
Font filed a 422-page motion to dismiss the petition and
dissolve the injunction, raising the applicability of the
litigation privilege, the paucity of details in the
allegations, the petition's reliance on
"psychoanalytical analysis" and "theatrical
representation of facts," and an argument that emailed
and electronically-filed pleadings and communications ...