In Ferlauto v. Hamsher (1999) 74 Cal.App.4th 1394, the appellate court concluded the "imaginative phrase 'Kmart Johnnie Cochran'" was not actionable, but was "a lusty and creative expression of contempt, too loose and figurative to be susceptible of being proved true or false. " (Ibid.) The Ferlauto court noted that "the phrases, 'creepazoid attorney' and 'loser wannabe lawyer' are classic rhetorical hyperbole which 'cannot "reasonably be interpreted as stating actual facts."' ( Milkovich v. Lorain Journal Co. 1990 497 U.S. 1, 20 . . .) The use of curse words, although not in good taste, are of course not to be taken literally. Such expressive phrases are merely name-calling of the 'sticks and stones will break my bones' variety. They are epithets and subjective expressions of disapproval, devoid of any factual content, reflecting the speaker's 'vague expressions of low esteem' for the subject." ( Ferlauto v. Hamsher, supra, 74 Cal.App.4th at p. 1404.)