In 600 West 115th Street Corp. v. Von Gutfeld, 80 N.Y.2d 130, 603 N.E.2d 930, 589 N.Y.S.2d 825 (1992), the court dismissed a claim based on a statement made by defendant at a Community Board meeting that a lease "is as fraudulent as you can get and smells of bribery and corruption" (p. 135), stating that "the type of forum is relevant because reasonable listeners arrive armed with the knowledge that deliberations are in progress, that no expertise is required of those who choose to speak, and that robust, controversial debate is expected; . . . (and) reasonable listeners in such circumstances arrive with an appropriate amount of skepticism" (p. 141).