To: Senior Partner<\/p>\n
From: <\/p>\n
Date: November 30, 2021<\/p>\n
Re: New client Pikop Andropov<\/p>\n
Facts<\/p>\n
Our client, Pikop Andropov, is seeking legal advice following an encounter with a rancher while canoeing on the River. On a clear day in early June 2021, Pikop and Kate entered the River at Monolith ranch, a public access point. At around 10am they encountered a four foot high barbed wire fence that ran under and over the river, extending in either direction as far as was visible. There were no warnings or visible dwellings. The river was three feet deep and flowing fast enough, that the only safe method to pass the fence was to do so on land. Pikop and Kate exited the river and only went as far off the riverbank as was necessary to reach solid ground and safely cross the fence. Kate was first to scale the fence, followed by the canoe and finally Pikop. While crawling between the barbed wire strands, Pikop heard gunshots. They were followed by a man, Mr Buzzoff, who was yelling at them to get off his property. He took pictures of them and mention that he would find out who they were. Mr. Buzzoff was holding a long gun with both hands, while Pikop and Kate were not in possession of any weapons. Pikop made it through the fence and proceeded to get back in the canoe with Kate as quickly as was possible. While on land they did not damage any part of the land besides trampling some grass. Together they paddled downstream without encountering any other man-made obstacles and never exited the canoe until they reached Ottomas park, another public access point.<\/p>\n
Buzzoff did not do any physical harm to Pikop, but did cause emotional harm. Since this encounter, Pikop has been unable to get any consistent sleep. She fears for her safety when outside and is unable to walk by herself anymore. When nobody is available or willing to go with her to class, she stays home. This has impacted her ability to satisfy her academic responsibilities at the University.<\/p>\n
Issues<\/p>\n
Is Pikop liable for tesspass?<\/p>\n
Did Pikop enter Mr. Buzzoff\u2019s land?<\/p>\n
Did Pikop have a legal right to enter the land?<\/p>\n
Can Pikop claim necessity as a defense to trespass?<\/p>\n
What damages may Pikop be liable for?<\/p>\n
Can Pikop recover under an intentional infliction of emotional distress (IIED) claim?<\/p>\n
Was the conduct extreme and outrageous?<\/p>\n
Was the conduct intentional or reckless?<\/p>\n
Was the threshold for severity of distress met?<\/p>\n
Was Mr. Buzzoff\u2019s conduct priviledged under the circumstances?<\/p>\n
Brief Answers<\/p>\n
Pikop was trespassing when she scaled the fence. However, Pikop may be successful with a necessity defense due to the inherently dangerous situation. Pikop will be at most liable for nominal damages.<\/p>\n
Pikop will most likely be able to recover under IIED if she has documentation of her symptoms. Since Buzzoff was not protecting his home, his conduct was not privileged and he will likely fail to escape liability.<\/p>\n
Discussion<\/p>\n
Pikop is looking for advice and possible legal remedies. There is possible tortious conduct on both sides. Pikop may have trespassed on Mr. Buzzoff\u2019s land, but it may have been necessary. On the other hand, Mr. Buzzoff was attempting to expel a trespasser. Although one has the legal right to exclude others from their property, the way it was executed may bring rise to an IIED claim; Pikop\u2019s best chance for recovery.<\/p>\n
Is Pikop liable for trespass?<\/p>\n
A landowner’s general property right to exclude people from her land is protected by the United States Constitution. Trespass is the term used to describe an infringement of the right to exclude. Trespasses are illegal entries into another person’s property done intentionally, without the owner’s consent and without the owner’s legal right to do so. As a result, Pikop is guilty of intentional trespass so long as she interferes with the plaintiff’s right to exclude with the goal of doing so on purpose. An entrance resulting from purposeful action is a trespass even if the trespasser did not want to trespass or did not know that her behavior would be considered a trespass, unless a court determines that the trespasser’s error was excusable due to necessity. If the landowner gives his or her assent to an access, the intrusion is clearly not improper and does not constitute a trespass. The authority granted by the landowner to access the property is referred to as an license. However, the landowner has the right to rescind her authorization at any moment. If she does, the licensee will be considered a trespasser if he continues to stay on the property.<\/p>\n
Did Pikop enter Mr. Buzzoff\u2019s land?<\/p>\n
In Day v Armstrong the plaintiff sought declaratory judgement of his right to float on the portion of the North Platte River where it flows on the defendants\u2019 land. The defendants alleged that they have the right to restrict the plaintiff from fishing, boating, or doing similar activities on or along the river. It was also alleged that permitting such uses of the river would prevent the Defendants to profitably operate the ranch. The court held that although the defendant owns the land underneath the river, the river itself is state property as stated in the state constitution (Art. 1, \u00a7 31, and Art. 8, \u00a7 1). In addition, the land is subject to an easement concerning the right of way of the river through the defendant\u2019s land as it naturally flows. As such, the public has the right to use to use the river and river bank between the high-water marks for lawful purposes such as walking, wading or floating watercraft. With proper licensure and permission from the state, hunting and fishing within the clearly defined boundaries of the riverbed is also permitted. By floating in a canoe on the river, Pikop did not trespass as she was still on public property even though it may have been within the boundaries of private land. However, the moment she left the riverbank to cross the fence, she was on Mr. Buzzof\u2019s land without his permission or a legal right and a trespasser in the most basic sense.<\/p>\n
Did Pikop have a legal right to enter the land?<\/p>\n
In Edgcomb v Lower Valley Power & Light the court held that a valid pre-existing easement is a legally protected interest sufficient to dismiss a trespass claim. Lower Valley Power held a valid easement to install and maintain power lines and was granted its administrative request to replace the power line with fiber optic cables. The landowner filed suit claiming trespass and injunctive relief. He claimed to have the right to exclude the power company. Trespass requires an intentional entry of land without a right or permission. At face value, the power company would be trespassing. However, they had a legally protected interest to enter the land for the purpose of installing cables, in the form of an easement. One of the primary tenants of owning land, is the right to exclude others. To claim trespass, one must have that exclusionary right. However, a valid easement defeats the right of exclusion. As a result, the power company prevailed, and the court held that the easement was enough to give them the legal right to enter the land even if the landowner disapproves. In Pikop\u2019s case, the river was subject to an easement which permits the operation of watercraft. While Pikop was canoeing on the river, she was within the bounds of the easement just like Lower Valley Power & Light. By canoeing, Pikop was exercising her legal right to be on the river and was not a trespasser until she left its confines. <\/p>\n
Can Pikop claim necessity as a defense to trespass?<\/p>\n
Since Pikop is been accused of trespassing on someone’s property in a civil case, she may be entitled to assert certain defenses against the charge. For instance, in Ploof v Putnam 81 Vt. 471, the defendant unmoored the plaintiff\u2019s ship that was docked on his private island. The ensuing storm caused damage to the vessel and harm to the people in it. The plaintiff\u2019s claim that the unmooring was a trespass and that the defendant had a duty to leave it there prevailed. The court held that the gale caused a necessity which justified mooring the sloop to the private dock. Similarly, if a person is travelling on a highway and there is an obstruction, he may avoid it by crossing over the adjacent land I.D. \u00a7 474. In Pikop\u2019s case, she trespassed when she left the riverbank to cross the barbed wire fence. However, if it is demonstrated that the intrusion was made due to necessity, it will not be considered a trespass.<\/p>\n
If the inference arose in a situation where it was required but permission could not be obtained in a reasonable amount of time, there may be a defense to trespass. It is required for the defendant to demonstrate that there was an evident and immediate risk to person or private property, and that the defendant honestly thought on reasonable grounds that the conduct was necessary to protect the person or property. As long as she does an act that would otherwise be a trespass to another’s private property in order to prevent a disaster or from hurting personal property or people, she is not considered to be committing a trespass to Buzzoff\u2019s private property interest. Her ability to do so is limited to the following conditions: she genuinely and reasonably thought that her action was required; and the action she took was reasonable under the circumstances.<\/p>\n
What damages may Pikop be liable for?<\/p>\n
In Bellis v Kersey the court held that in a trespass claim the court can award either nominal or actual damages but not both. The court granted damages to the Kersey\u2019s resulting from a dispute over the precise location of the border between the Bellises and Kersey\u2019s property. In light of the events presented, the bench trial found that there was in fact trespass by Bellis. Both actual and nominal damages were awarded. Nominal damages are \u201cin name only\u201d and usually in the quantity of 1$. The supreme court understood that the 1300$ in actual Damages was proven but the $1500 in nominal damages was for re-building the fence. The Supreme court held that nominal damages are only for cases where actual damages cannot be proven. Because the lower court awarded both damages, the nominal damages were omitted.<\/p>\n
If Pikop\u2019s testimony is assumed to be accurate she most certainly trespassed. Day v Armstrong clarified that rivers and the riverbed alongside them are state property and accessible to all who use them for a legal purpose. Since Pikop left the riverbank to cross the fence, she was no longer on state land and a trespasser. The Laramie River is known to be at or close to its peak velocity in June and crossing a barbed wire fence in strong current is a potential life or death risk. Crossing the fence on stable ground would most likely be considered necessary to avoid excessive risk of physical harm or drowning.<\/p>\n
Intentional Infliction of Emotional Distress<\/p>\n
Intentional infliction of emotional distress (IIED) often entails some kind of action that is so heinous that it causes the victim to suffer serious emotional pain. In such circumstances, the victim may be able to obtain compensation from the individual who caused the mental anguish. However, not every offensive behavior falls under the category of deliberate infliction of emotional distress. People in society must, by necessity, cope with a certain amount of rudeness or offensiveness on the part of others. Recovery for the emotional damage caused by the behavior, on the other hand, becomes possible when the conduct reaches a genuinely deplorable degree of conduct. The Supreme Court’s decision in Snyder v Phelps (2010) suggested a shift away from assigning culpability for IIEDs. The Court overturned the jury finding that established IIED liability because “[using the IIED tort] would constitute an undue risk that the jury would penalize [the plaintiff] for its opinions on topics of public concern,” according to the Court.<\/p>\n
Was the conduct extreme and outrageous?<\/p>\n
In any claim for IIED, establishing what precisely constitutes extreme and outrageous behavior is one of the most critical questions to consider. Even if the actor acted with malice and\/or ill purpose, this is a prerequisite for a claim for intentional infliction of emotional distress. Extreme and outrageous behavior extends beyond acts that are malevolent, damaging, or offensive in nature<\/p>\n
In Garcia v Lawson, the court defined the meaning of \u201cextreme and outrageous\u201d conduct. The case concerned Garcia who claimed IIED. She allegedly suffered battery and rape at the hands of her boyfriend. Lawson was a police officer in Cheyenne who refused to provide a rape kit to Garcia, claiming that the police department can\u2019t do anything about boyfriend\/girlfriend incidents. The court cited Leithead which defined outrageous conduct as \u201cconduct which goes beyond all possible bounds of decency, is regarded as atrocious, and is utterly intolerable in a civilized community\u201d (cite). Although lawson was offensive and insensitive, the court decided a threshold had to be established for what conduct goes beyond the bounds of decency. Relying on Drzejza v Vaccaro, actions that are socially unacceptable such as condescending or obnoxious behavior did not meet that threshold (cite). Mere insults and annoyance are on their own not extreme and outrageous enough to constitute IIED, and judgement for the defendant was affirmed.<\/p>\n
Hatch v State Farm Insurance Co. further spelled out the boundaries of outrageous conduct, where evidence of discomfort, crying and being upset does not reach the standard or IIED. After the Hatch\u2019s family house was damaged in a fire, they filed an insurance claim with State Farm. The fire was ignited by a wood burning stove. Fireman found a gas canister in the garage and gasoline samples in the carpet. State Farm Insurance cited the evidence as proof of arson and refused a payout. The ensuing litigation and delay of reimbursement caused emotional distress to Hatch. The court referenced the Restatement (Second) of Torts \u00a7 46 cmt. D, p. 73 (1965)<\/p>\n
Liability has been found only where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community. Generally, the case is one in which the recitation of the facts to an average member of the community would arouse his resentment against the actor, and lead him to exclaim, “Outrageous!”<\/p>\n
The Hatches provided evidence that the claims process included excessive interviews, using flashlights to complete forms in the cold and dark, dealing with an aggressive and hostile State Farm attorney, and required them to take sick and vacation leave in order to abide by a 60 day deadline. Applying the restatement, the conduct was not \u201cintolerable in a civilized community\u201d, nor would it cause a reasonable community member to exclaim \u201coutrageous!\u201d. Providing little solace, the district court did admit that the conduct was insensitive but nevertheless not outrageous enough for IIED. <\/p>\n
In order to achieve this degree of indecency, the behavior must go above all reasonable expectations of decency. The use of common insults or rudeness does not generally qualify as severe and outrageous behavior, however it is possible for them to grow to that level if there is some form of unique connection between the parties. Ordinary insults or acts may be elevated to the level of severe and outrageous conduct if the perpetrator is aware that the victim is especially vulnerable to emotional distress as a result of a physical or mental ailment or abnormality. Despite the fact that exercising a legal right may cause serious mental damage, exercising that right will never be considered deliberate infliction of emotional distress by the court of law.<\/p>\n
Whether Mr. Buzzoff\u2019s actions would be tolerated in a civilized society and if they would cause a reasonable member to scream \u201coutrageous!\u201d is a matter of discussion rather than fact. Certainly, they were inhospitable and intimidating. Viewing the circumstances in a light most favorable to Pikop, it is definitely plausible that typical members of a rural community would find the discharge of a firearm to dispel a trespasser to be intolerable.<\/p>\n
Was the conduct intentional or reckless?<\/p>\n
In Bevan v Fix, the district court\u2019s claim that an isolated incident cannot suffice an IIED claim was overruled. Fix allegedly physically harmed Jones, the ex-wife of Bevan, while her children Steven and Brittany watched. Shortly thereafter, Steven began chocking classmates in school and Brittany had trouble sleeping. Counselors diagnosed Steven with PTSD and Britany with depression. The court cited Restatement, Second, Torts \u00a7 46(2)(a) which specifies that the claimant must prove:<\/p>\n
That the conduct was \u201cextreme and outrageous\u201d;<\/p>\n
That such conduct was directed at a third person;<\/p>\n
That the claimant is a member of the immediate family of the third personal;<\/p>\n
That the claimant was personally present when the extreme and outrageous conduct took place,<\/p>\n
That the claimant sustained severe emotional distress as a result of that conduct (whether or not the claimant sustained bodily harm); and<\/p>\n
That the person whose conduct is complained of \u201cintentionally\u201d or \u201crecklessly\u201d caused severe emotional distress to the claimant.<\/p>\n
The district court held that the first element is not met since there was no recurring pattern of abuse. The Supreme court disagreed, mentioning that the illustrations in the restatement all relate to isolated incidents. Requiring plaintiff\u2019s to show \u201ca continuing course of abuse\u201d would be a burden inconsistent with the rest of the Restatement \u00a7 46. The court also clarified the specific threshold necessary to meet recklessness in the sixth element. The assault at issue was of a nature that would cause emotional harm to relatives and bystanders and as such Fix must have been aware of such an outcome. Fix\u2018s action had a higher degree of risk than mere negligence and his knowledge of the collateral emotional damages raised the bar to recklessness (42 P.3d 1013).<\/p>\n
It can be stated with near certainty that Buzzoff acted with intent to intimidate. Firearms don\u2019t fire on their own, and even if Buzzoff is given the benefit of doubt at the very least the discharge was due to negligence. Whether the discharge was due to intent to harm or mere negligent handling, it was reckless nonetheless. Any reasonable person would understand, or should understand, that running after someone with a firearm while yelling obscenities and firing rounds could cause stress and emotional harm.<\/p>\n
Was the threshold for severity of distress met?<\/p>\n
The emotional distress resulting from extreme and outrageous conduct must reach a “severe” degree in order to meet the elements of an intentional infliction claim, according to the statute of limitations. It is difficult to define exactly what constitutes significant emotional distress, and plaintiffs must demonstrate to a jury that the emotional pain they suffered reached a degree of severity that justifies an award for intentional infliction of emotional distress. There are certain parameters that may be used to decide whether an emotional problem qualifies as mental anguish or not.\u00a0<\/p>\n
Claims of IIED without specific evidence of how the offensive action adversely effected claimant\u2019s life should be dismissed as explained in Hoblyn v Johnson. Hoblyn\u2019s sixteen year old daughter accused her father of physical abuse. The Department of Family Services advised to send the daughter to another family member for a \u201ccooling off\u201d period. While accusing the father of abuse, Michelle Hoblyn (the mother) sent her daughter away from Cheyenne to temporarily stay with her grandparents in Nebraska. Hoblyn sued the grandparents for interference with their parent-child relationship by depriving her of visitation rights, and larceny in regard to the daughter\u2019s horse. The parents also alleged that the grandmother\u2019s outrageous conduct inflicted among them emotional distress. The district court mentioned that one way Hoblyn could provide evidence that the distress is severe was if she sought counseling or other professional help. It held that Hoblyn provided bold IIED claims but no supporting evidence. The supreme court affirmed and mentioned that \u201cevidence of the impact of this alleged distress on their lives such as missed work, inability to sleep or engage in hobbies and activities previously enjoyed, diminished ability to socialize or handle the necessary functions of everyday life, or memory loss\u201d was never provided (cite). Seeking professional help is not required but in conjunction with other physical manifestations of the emotional harm, the plaintiff can provide sufficient evidence for the jury to determine that severe emotional distress existed.<\/p>\n
In contrast to Hoblyn which showed what is inadequate evidence to prove emotional distress, KIanzler succeeds in meeting that threshold. In Kanzler v Renner, the court further specifies what emotional distress may include and how to document it. Kanzler was a police dispatcher and claimed that Renner sexually harassed her in a utility closet. Three months later, she resigned from her position and began seeing a counselor who diagnosed her with depression and post-traumatic stress disorder. The court relied on the Restatement 2nd \u00a7 46 which states that \u201call highly unpleasant mental reactions, such as fright, horror, grief, shame, humiliation, embarrassment, anger, chagrin, disappointment, worry and nausea\u201d are included under IIED. In order to document the evidence of the emotional harm, Kanzler was evaluated by a counselor, her family practitioner and at the request of the City of Cheyenne a forensic psychologist. The court held that the opinions of three experts provided sufficient evidence to have the jury decide the severity of the distress (cite). <\/p>\n
In Wilder v Cody Country Chamber of Commerce, the court reaffirmed that the duration of the distress is an important factor in determining its severity. Wilder was the chief administrator for the Chamber who was forced to resign. In 1988, Wilder was contacted by the IRS for delinquent taxes and failed to disclose the Chamber\u2019s financial problems. Wilder was served with a memorandum from the Chamber\u2019s President clarifying that he was still under the probationary period and could be fired at any time. Wilder was unable to find employment with the Park County Travel Council or the Yellowstone Airport Board because the President objected to a hiring of Wilson and proposed alternative Chamber employees. The Wyoming Supreme Court considered the Chamber\u2019s actions prior and post Wilder\u2019s termination. Persuaded by the claim that Wilder became a \u201cscapegoat\u201d for the Chamber\u2019s financial ailments, recovery would only have been permitted if the distress was severe. The chamber\u2019s continued efforts to prevent Wilson from obtaining employment after his termination were deemed outrageous to the extent of the standard established in the Leithead case. In particular the court reasoned that \u201cNo reasonable person expects a former employer to mount an active campaign to prevent a former employee from obtaining work\u201d (cite) meaning that it was primarily the continued duress Wilder endured that allows him to recover under IIED.<\/p>\n
Courts have consistently ruled that severity of the distress must be documented and mere insults would not suffice. Continued abuse that happens regularly would be help support the severity element. In Pikop\u2019s case, the incident was a one time ordeal, but the effects have continued. Her continued quest for emotional support with counselors and friends would strengthen the argument that the harm was everlasting. Pikop has been diagnosed by professionals and although not required, as evidenced in Kanzler v Renner, it is additional evidence that strengthens the case for satisfying the severity element.<\/p>\n
Was Mr. Buzzoff\u2019s conduct privileged under the circumstances<\/p>\n
Even if the defendant intended to cause emotional harm, but they acted within the bounds of the law, they cannot be liable for IIED as was held in Leithead v American Colloid Co. Leithead was an employee at American Colloid and past his probationary period. The employee handbook implied that after the probationary period, an employee is no longer employed at will and can only be fired for cause. Leithead was fired due to a suspicion that he was leaking company secrets to a competitor. The dismissal caused emotional distress to leithead. The court held that his employer might have a complete defense if the distress was caused solely by a discharge permissible within the bounds of his contract. The court relied on a quote from the Restatement Second, Torts \u00a7 46 comment (g) which states \u201cThe actor is never liable where he has done no more than to insist upon his legal rights in a permissible way, even though he is well aware that such insistence is certain to cause emotional distress.\u201d The distress was deemed not severe and even if it was, it was related to a Slander claim and unrelated to the discharge. Hence, the district court\u2019s decision to grant summary judgement for American Colloid Co. was affirmed.<\/p>\n
State v Schloredt concerns the use of excessive force to repel a trespasser. The defendant was attempting to shoot a trespasser who was guiding cattle across the ranch but shot the horse instead. Charged with aggravated assault and battery, he claimed that the discharge of his firearm was in self-defense and to preserve the valuable hay land. The court held that if there is a trespass the owner \u201chas the right to repel or terminate an unlawful intrusion thereon. But he has no right to use any more force than necessary\u201d (cite). In this case, the trespasser was already leaving the land, so the appropriate use of force was very limited. The level of force one is authorized to use is dictated by the circumstances and what would be necessary to prevent a trespass. If one is not defending a domicile, the use of deadly force is even more restrictive. Given that Schloredt was not defending his home and was not in imminent danger of harm or serious bodily injury, shooting at the trespasser was deemed excessive. As a result, Schloredt\u2019s self-defense claim was dismissed.<\/p>\n
Landownership gives landowners the legal right to exclude others from the land. Reasonable force may be used to do so, but the level appropriate is dictated by the circumstances. If the landowner is defending a dwelling or place of residence, the use of force may be greater. An imminent threat of death or serious bodily injury may further increase the level of force that is privileged. There is no steadfast rule that allows deadly force across the board, and such cases must be decided on a case by case basis. State v Schloredt, demonstrated that deadly force is not privileged in an instance where the trespasser is not a danger to the landowner or his\/her dwelling. Pikop was in a very analogous situation and if the court abides by precedent, Buzzoff\u2019s use of deadly force will not be privileged under the circumstances. <\/p>\n
Conclusion<\/p>\n
According to the law,\u00a0anybody who owns property owns the airspace above it as well as the earth below it, to a reasonable height or depth in accordance with the actual use of the property. Land encompasses much more than just the tangible dirt under our feet. The rights to all natural resources on the property have been transferred to the landowners by the government. A direct, purposeful, and actionable violation of a person’s right to land is required in the case of trespass on private property. To be considered purposeful, the trespasser must have meant to enter that specific piece of property. It is not required for the trespasser to have knowledge that they are trespassing. As such, Pikop trespassed even though she may not have known that anything beyond the riverbank was private property. Since doing so was necessary to protect her safety she will only be liable for any actual damage to Buzzoff\u2019s land she may have caused under the defense of necessity. Buzzoff on the other hand, may be liable for any emotional harm he caused to Pikop. Pikop will not necessarily have to prove that she missed classes or sought counseling, as long as her distress was extreme enough that no ordinary person would be expected to endure. If Buzzoff wishes to defend his actions by claiming they were privileged under the circumstances, he would have to clear large burden as he was neither protecting a dwelling or in imminent danger of his life.<\/p>\n","protected":false},"excerpt":{"rendered":"
To: Senior Partner From: Date: November 30, 2021 Re: New client Pikop Andropov Facts Our client, Pikop Andropov, is seeking legal advice following an encounter with a rancher while canoeing on the River. On a clear day in early June 2021, Pikop and Kate entered the River at Monolith ranch, a public access point. At […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[10],"class_list":["post-79106","post","type-post","status-publish","format-standard","hentry","category-research-paper-writing","tag-writing"],"_links":{"self":[{"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/posts\/79106","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/comments?post=79106"}],"version-history":[{"count":0,"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/posts\/79106\/revisions"}],"wp:attachment":[{"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/media?parent=79106"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/categories?post=79106"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/papersspot.com\/blog\/wp-json\/wp\/v2\/tags?post=79106"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}