d (1977). 11 . Sands v. Living Word Fellowship, 34 P.3d 955, 960 (Alaska 2001). 12 . See, eg., Milkovich, 497 U.S. at 19, 110 S.Ct. 2695 (rejecting wholesale defamation exemption of all statements in form of opinion, but holding that "statement on matters of public concern must be provable as false before there can be liability under state defamation law""); see also Sands, 34 P.3d at 960. 13 . Hustler Magazine, Inc. v. Falwell, 485 U.S. 46, 50-51, 108 S.Ct 876, 99 LEd.2d 41 (1988) (quoting Bose Corp. v. Consumers Union of United States, Inc., 466 U.S. 485, 503-04, 104 S.Ct. 1949, 80 L.Ed.2d 502 (1984)). 14 . Sands, 34 P.3d at 960 (quoting Milkovich, 497 U.S. at 24, 110 S.Ct. 2695 (Brennan, J., dissenting)). 15 . See Wilson v. Grant, 297 N.J.Super. 128, 687 A.2d 1009 (App.Div.1996) (<HOLDING>). 16 . See, eg., Leidholdt v. L.F.P., Inc., 860
holding radio broadcasters description of plaintiff as stalker some little weasel a vicious swine a sick cookie and sick no good pot smoking wife beating skunk was not defamatory holding that description was sufficiently detailed holding that a prosecutors description of some of defense counsels arguments as red herrings and smoke and mirrors was not inappropriate holding beating as disproportionate and beyond hazy border where suspect offered no resistance holding that words which expressly refer to adequate legal description provide nucleus of description that is legally sufficient for statute of frauds