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Case 18-2868, Document 276, 08/09/2019, 2628224, Page37 of 77 Steinhilber court held, “even apparent statements of fact may assume the character of statements of opinion, and thus be privileged, when made in public debate, heated labor dispute, or other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or hyperbole.” /d. (internal quotations and brackets omitted); see Gross, 623 N.E.2d at 1169 (“we stress once again our commitment to avoiding the ‘hypertechnical parsing’ of written and spoken words for the purpose of identifying ‘possible “fact[s]”’ that might form the basis of sustainable libel action”) (quoting Jmmuno AG, 567 N.E.2d at 1282). To the same effect is this Court’s citation to a Louisiana Supreme Court decision for the 6e6 proposition that “‘[w]ords which, taken by themselves, would appear to be a positive allegation of fact, may be shown by the context to be a mere expression of opinion or argumentative influence.”” Adelson, 973 F. Supp. 2d at 488 (emphasis supplied; quoting Mashburn v. Collin, 355 So. 2d 879, 885 (La. 1977)). It also is important to take into account, as Steinhilber requires, that Mr. Barden was directing the January 2015 statement to a discrete number of media representatives who were aware of plaintiff's “original” and “new,” joinder-motion allegations and who were requesting a response from Ms. Maxwell to the “new” allegations. These newspaper reporters and other media representatives would have the point Mr. Barden was making—the opinion he was expressing—namely, that there was good reason to believe plaintiff was fabricating allegations for her purposes. In the context of the media circus that ensued the public filing of the joinder motion and the media’s repeated and insistent requests for an immediate response from Ms. Maxwell, it is highly unlikely any media-recipients of the January 2015 statement expected anything other than a statement equivalent to the March 2011 statement condemning the allegations; and it is highly likely all the media-recipients understood the statement to be a 30