{"id":7577,"date":"2020-06-29T20:47:04","date_gmt":"2020-06-30T01:47:04","guid":{"rendered":"https:\/\/www.nickortizlaw.com\/?p=7577"},"modified":"2024-01-11T17:35:22","modified_gmt":"2024-01-11T22:35:22","slug":"rouleau-v-liberty-life-court-assigns-no-weight-to-surveillance-video","status":"publish","type":"post","link":"https:\/\/www.nickortizlaw.com\/rouleau-v-liberty-life-court-assigns-no-weight-to-surveillance-video\/","title":{"rendered":"Rouleau v. Liberty Life – Court Assigns No Weight to Surveillance Video"},"content":{"rendered":"

Case Name:\u00a0<\/strong>Michelle R. Rouleau v. Liberty Life Assurance Company of Boston<\/p>\n

Court:\u00a0<\/strong>U.S. District Court for the Western District of Michigan<\/p>\n

Date of Decision:\u00a0<\/strong>January 25, 2017<\/p>\n

Type of Claim:\u00a0<\/strong>Long-term disability<\/a> under 29 U.S.C. \u00a7 1132(a)(1)(B), a civil enforcement provision of the Employee Retirement Security Act (\u201cERISA\u201d)<\/a><\/p>\n

Insurance Company:\u00a0<\/strong>Liberty Life Assurance Company of Boston<\/a><\/p>\n

Claimant\u2019s Employer:\u00a0<\/strong>Sparrow Hospital<\/p>\n

Claimant\u2019s Occupation \/ Job Position: <\/strong>Registered Nurse<\/a><\/p>\n

Disabilities:\u00a0<\/strong>Intractable lower back pain, assessed as thoracolumbar spine pain<\/a>, thoracic disc displacement, thoracic spondylosis, lumbar spondylosis, and myofascial pain. The plaintiff has had a lumbar facet rhizotomy for lumbar spine pain, bilateral facet block procedures, a series of epidural injections, and a left transforaminal epidural steroid injection. As conservative treatments failed, she underwent lumbar fusion surgery. Although her back pain initially improved, she continued to have \u201ca lot of left leg pain,\u201d which limited her walking. She could not return to work and became eligible for long-term disability benefits effective September 4, 2012.<\/p>\n

Ms. Rouleau continued to seek treatment for her pain. On October 22, 2012, Dr. Andary reported the results of an electrodiagnostic evaluation of Ms. Rouleau. He noted that Ms. Rouleau had undergone epidural steroid injections without lasting success and back surgery with fusion. Ms. Rouleau reported no pain in her right leg after surgery, but the pain in her lower back and left leg had persisted. She described the pain as a five to six out of ten. She noted that she \u201cstumbles sometimes because she catches her left toe and foot when she is walking as it does fatigue.\u201d Dr. Andary found no electrodiagnostic evidence for certain conditions that could have explained her symptoms. He suspected that nerve root irritation caused her symptoms.<\/p>\n

Ms. Rouleau saw Dr. Winkelpleck again on October 30, 2012, after having an injection for left total knee pain. She told him that she still had some numbness in her toes but that the pain in her left leg now extended only to her knee instead of all the way to her foot. Her back pain was minimal. Again, the relief did not last. In December 2012, Ms. Rouleau returned to Dr. Winkelpleck for an evaluation after having injection therapy for her continued lower left extremity pain following lumbar fusion and decompression. She stated that the injection provided no relief. She complained principally of \u201cleft gluteal and lateral thigh pain on the left side.\u201d Her back pain was still \u201cthere but nothing compared to the left lower extremity radicular component.\u201d Ms. Rouleau was \u201cfrustrated and wants to know what to do next as far as alleviating her pain.\u201d<\/p>\n

Ms. Rouleau saw Dr. Winkelpleck again on February 12, 2013. His notes state that she \u201ccontinues to have left lower extremity and gluteal pain. Her back pain is not significant at this point. It is more of an annoyance. The foot pain that was present and just burning all the time has resolved, and now the pain is more proximal in the gluteal region . . . .\u201d Dr. Winkelpleck found that \u201cat this point, it\u2019s reasonable to proceed with a spinal cord stimulator, trial in the pain clinic.\u201d<\/p>\n

He commented that Ms. Rouleau \u201chas not returned to work but will consider returning to work as long as there is a sit-stand option that does not require a lot of bending and lifting which is reasonable.\u201d He planned to see her again after a spinal cord stimulator trial.<\/p>\n

Ms. Rouleau returned to the Pain Management Center in February 2013 for evaluation for spinal cord stimulation. It was noted that Ms. Rouleau had received epidural steroid injections, most recently in October and November of 2012, that she had lumbar fusion surgery in June 2012, and that she was not a candidate for another surgery. After evaluation, Dr. Gundamraj and Nurse Simons (R.N., M.S.O.S.) sent Ms. Rouleau\u2019s case to a \u201ccase conference with a multi-disciplinary meeting of physicians, case managers, pain psychology, nurse practitioners, and physical therapy to further determine a plan of care.\u201d<\/p>\n

Dr. Gundamraj and Nurse Simons noted that Ms. Rouleau \u201csuffers from severe pain, which has been present for more than one year . . . [and] has failed to achieve satisfactory pain relief with all modalities of multidisciplinary pain management, including interventional techniques, cognitive-behavioral psychotherapy, medication management, and rehabilitation.\u201d They commented that Ms. Rouleau\u2019s \u201cpain remains significant, limits activities of daily living, and severely diminishes [her] quality of life.\u201d<\/p>\n

Dr. Winkelpleck evaluated Ms. Rouleau on February 12, 2013. He noted that she \u201ccontinued to have left lower extremity and gluteal pain\u201d and that \u201cher back pain is not significant at this point.\u201d He commented that foot pain \u201cthat was present and just burning all the time has resolved and now the pain is more proximal in the gluteal region[;]\u201d and that \u201c[s]he does have difficulty sleeping on the left side.\u201d He determined that \u201c[a]t this point it\u2019s reasonable to proceed with a spinal cord stimulator trial [at] the plain clinic.\u201d He stated that Ms. Rouleau \u201chas not returned to work but will consider returning to work as long as there is a sit-stand option that does not require a lot of bending and lifting which is reasonable.\u201d He added that he would see her again after the spinal cord stimulator trial at the pain clinic. A note from Dr. Winkelpleck dated February 12, 2013, is addressed \u201cto whom it may concern\u201d and states that Ms. Rouleau will remain off work through March 22, 2013, for ongoing treatment for back pain, and that it remained to be determined when she would return. A note from Dr. Winkelpleck dated February 12, 2013, is addressed \u201cto whom it may concern\u201d and states that \u201cMs. Rouleau is under my medical care. She may NOT work at a position with direct patient care. However, she would be able to work in a sitting position with a sit to stand option, without bending, lifting, or twisting.\u201d<\/p>\n

Dr. Camala Riessinger, a psychologist from the Pain Management Center, evaluated Ms. Rouleau on March 13, 2013. (Id., PageID.261.) Ms. Rouleau indicated to Dr. Riessinger that she was eager to work again. Dr. Riessinger found Ms. Rouleau \u201cvery motivated to do everything she can to improve her condition.\u201d Dr. Riessinger administered the MMPI-2 in April 2013 \u201cto better understand this patient\u2019s level of functioning, her ability to cope with chronic pain, and to help with treatment planning to see if she is a good candidate from a psychological standpoint for an implantable pain control device.\u201d Dr. Riessinger found that Ms. Rouleau \u201chas no evidence of a thought disorder . . . no history of substance abuse . . . [and] realistic expectations with regard to the stimulator.\u201d Ms. Rouleau had a trial spinal cord stimulation procedure on June 17, 2013.<\/p>\n

At the time of her discharge, Ms. Rouleau reported that the spinal cord stimulation was providing approximately 80 % coverage of the previously painful area and 50% pain relief. The next day, she reported pain relief that was \u201csignificant\u201d but \u201cnot complete,\u201d and a pain score of eight out of ten. The treating physician, Dr. Silverstein, reprogrammed the device, after which Ms. Rouleau reported: \u201c100% coverage of the primary painful areas with about 50% pain relief, at least while sitting, standing, and walking briefly in the office.\u201d The day after that, Ms. Rouleau had a pain score of three out of ten.<\/p>\n

In July 2013, Defendant hired a company to conduct surveillance on Ms. Rouleau\u2019s home. Surveillance of the residence took place on July 6, 7, 8, 9, 13, and 16, 2013. Surveillance yielded no sign of Ms. Rouleau engaging in any activity on four days: July 6, 7, 8, or 16. On July 9, surveillance yielded a video<\/a> of Ms. Rouleau totaling approximately 12 minutes. The report states that the video \u201cdepicts the claimant as she walked, bent at the waist several times, appeared to clean the interior of the vehicle, and entered the vehicle. The claimant appeared to ambulate in a normal manner, without restrictions of the use of visible medical devices.\u201d The report describes the video quality as \u201caverage.\u201d On July 13, surveillance yielded a video of Ms. Rouleau totaling approximately 90 minutes. According to the report, the video depicts Ms. Rouleau \u201cwalking, bending at the waist, using a pool skimmer to clean a pool, moving several pieces of outdoor furniture, using a leaf blower and garden hose, traveling by car, getting gas, setting up an outdoor canopy, and conversing with others. The report notes that \u201cthe claimant appeared to ambulate in a normal manner, without restrictions of the use of visible medical devices.\u201d The report describes the video quality as \u201cfair.\u201d<\/p>\n

Ms. Rouleau had permanent placement of a spinal column stimulator on September 9, 2013. The next month, she presented at the Pain Management Center with intermittent mild to moderate pain. Her pain score ranged from three to five out of ten. She reported approximately 75% coverage of previously painful areas and a pain reduction of roughly 50%. She reported that she had been \u201cable to increase her activities significantly,\u201d albeit with flares of pain during activity. Overall, she was pleased with the results of the spinal cord stimulator. Two months later, she continued to report the same degree of coverage and pain relief. Her pain score ranged from three at best to five or six at worst. She described her pain as intermittent, \u201cmoderate pain of aching intensity, increasing particularly with standing and walking or bending.\u201d Her pain continued to interfere with her sleep. The record reflects that in addition to her back pain, Ms. Rouleau had carpal tunnel syndrome<\/a>\u00a0in both hands. She reported to Dr. Horner in 2012 that she had pain at a level seven or eight out of ten in her left hand; numbness in both hands; and had been dropping things. The condition worsened. Dr. McDermott performed\u00a0carpal tunnel\u00a0surgery on both her hands in the fall of 2013. Surgery ameliorated the\u00a0carpal tunnel symptom, but numbness and tingling remained present. Ms. Rouleau completed Activities Questionnaires at Liberty\u2019s request in 2012, 2013, 2014. The questionnaires track the deterioration the medical records reflect.<\/p>\n

In August 2012, two months after lumbar fusion surgery, the Plaintiff indicated she could sit for one to two hours, stand for half an hour, and walk for half an hour. She spent approximately ten hours a day in bed. On July 22, 2013, she indicated she could sit for 45 minutes to an hour, stand for fifteen minutes, and walk for fifteen minutes. She needed assistance in grocery shopping, cleaning, and doing laundry. Asked to describe in her own words what prevented her from engaging in any gainful employment, she answered, \u201cpain in back \u2013 leg pain \u2013 difficulty in sitting standing and walking for any length of time . . . can carry light objects \u2013 difficulty walking upstairs.\u201d On January 2, 2014, in her final activities questionnaire, Ms. Rouleau indicated there had been no change in the amount of time she could sit or stand and that she now spent fourteen hours a day in bed. She could drive a car for forty-five minutes. She needed assistance in grocery shopping, carrying groceries, cooking, cleaning, and doing the laundry. In response to the question asking what prevented her from engaging in any gainful employment, she wrote, \u201cno change.\u201d<\/p>\n

Definition of Disability in the Plan\/Policy:\u00a0<\/strong>Policy defines \u201cdisability\u201d or \u201cdisabled\u201d to mean that \u201cduring the Elimination Period and the next 24 months of Disability the Covered Person, as a result of Injury or Sickness, is unable to perform the Material and Substantial duties of [her] Own Occupation.\u201d The Policy further provides that after the 24 month period ends<\/a>, \u201cdisability\u201d or \u201cdisabled\u201d means that \u201cthe Covered Person is unable to perform, with reasonable continuity, the Material and Substantial Duties of Any Occupation.\u201d<\/p>\n

Benefits Paid?\u00a0<\/strong>Yes. The defendant has never disputed that Ms. Rouleau was entitled to benefits throughout the \u201cown occupation\u201d<\/a> period. In April 2014, as the beginning of the \u201cany occupation period\u201d in September approached, Defendant referred Ms. Rouleau\u2019s medical file for peer review to prepare for the end of the two-year \u201cown occupation\u201d period of benefits in September 2014.<\/p>\n

Basis For Denial \/ Termination of Benefits:\u00a0<\/strong>Relying exclusively on Dr. Patel\u2019s opinion for medical context, a vocational specialist determined that Ms. Rouleau could perform other occupations. Accordingly, Defendant concluded that Ms. Rouleau was not entitled to benefits under the Policy once the \u201cown occupation\u201d period expired. Defendant terminated Ms. Rouleau\u2019s benefits effective September 4, 2014.<\/p>\n

Procedural History: <\/strong>Ms. Rouleau appealed the decision. On appeal, Defendant again concluded that Ms. Rouleau was not entitled to benefits because, according to Defendant, she could perform work in other occupations.
\nThis lawsuit ensued.<\/p>\n

Key Physician Opinions:\u00a0<\/strong>Towards the end of the 24-month \u201cown occupation\u201d period, Dr. Patel conducted the peer review for the insurance company. Dr. Patel reviewed Ms. Rouleau\u2019s medical records but did not examine Ms. Rouleau personally. Dr. Patel did not speak directly with any of Ms. Rouleau\u2019s medical providers. Dr. Patel opined that based on the medical evidence, the claimant could lift 20 pounds occasionally and sit up to one hour at a time for a total unrestricted sitting in an 8-hour day with the ability to change positions for comfort. Standing and walking would be unrestricted. The prognosis is good for a return to full-time work with the above restrictions and limitations. The above limits would be considered permanent due to the chronic nature of the claimant’s condition.<\/p>\n

As part of the claimant\u2019s appeal, her primary care physician, Dr. Schaar, completed Liberty\u2019s Attending Physician\u2019s Assessment of Capacity form in February 2015. He opined that Ms. Rouleau had uncontrolled pain, could not function full-time in an occupational setting, and that this condition was permanent. Dr. Schaar\u2019s report was part of the record Defendant considered in deciding Ms. Rouleau\u2019s appeal.<\/p>\n

Issues:\u00a0<\/strong>In this case, the parties agree that Rule 500.2202 applies to the Policy, and the applicable standard of review is de novo. Where the de novo standard applies, the reviewing court’s role is to determine whether the denial of benefits was the \u201ccorrect decision.\u201d Perry v. Simplicity Eng\u2019g<\/em>, 900 F.2d 963, 966 (6th Cir. 1990). The plaintiff bears the burden of proof, and a preponderance of the evidence standard applies.\u00a0Javery v. Lucent Technologies, Inc. Long Term Disability Plan for Management or LBA Employees<\/em>, 741 F.3d 686, 700-701 (6th Cir. 2014). The court must review the \u201crecord before the administrator\u201d without granting \u201cdeference . . . or any presumption of correctness\u201d to the administrator\u2019s determination. Id. The de novo standard of review \u201capplies to the factual determinations as well as to the legal conclusions of the plan administrator.\u201d\u00a0Wilkins<\/em>, 150 F.3d at 613. A court should not hear or consider evidence not presented to the plan administrator in connection with a claim.\u00a0Perry<\/em>, 900 F.2d at 966. Indeed, a court must \u201csimply decide whether or not it agrees with the decision under review.\u201d Id.<\/p>\n

Holdings:\u00a0<\/strong>A preponderance of the evidence weighs in favor of a benefits award. The record evidence includes, without limitation, Ms. Rouleau\u2019s treatment records from the Sparrow Pain Management Center, which span February 2011 through December 2013 and encompass both medical and psychological reports; treatment records from the MSU Spine Center, spanning June 2012 through September 2013; a June 2012 post-operative report from Sparrow Hospital; records of radiology imaging and other diagnostic testing throughout 2011 \u2013 2013; records of treatment for\u00a0carpal tunnel syndrome\u00a0in 2012 and 2013; Dr. Patel\u2019s Peer Review Report of March 2014; the Transferrable Skills Analysis\/Vocational Review<\/a> dated April 10, 2014; Dr. Schaar\u2019s Assessment of Capacity dated February 5, 2015; Ms. Rouleau\u2019s Activities Questionnaires; and the award of disability benefits by the Social Security Administration.<\/p>\n

The administrative record includes both subjective and objective evidence<\/a> of Ms. Rouleau\u2019s impairment. The Court gives great weight to the Social Security Administration\u2019s (\u201cSSA\u201d) determination that Ms. Rouleau is totally disabled from employment. It is well-established that \u201c[a] determination that a person meets the Social Security Administration\u2019s uniform standards for disability benefits does not make her automatically entitled to benefits under an ERISA plan, since the plan\u2019s disability criteria may differ from the Social Security Administration\u2019s.\u201d DeLisle v. Sun Life Assur. Co. of Canada, 558 F.3d 440, 445-46 (6th Cir. 2009). But the SSA\u2019s determination is \u201cfar from meaningless.\u201d<\/p>\n

(1) Here, Defendant Liberty Life encouraged Ms. Rouleau to apply for Social Security disability benefits and financially benefited from her award of disability benefits. Defendant says that it reached a different conclusion from the Social Security Administration because, unlike the Social Security Administration, it was not required to follow the treating physician rule. Defendant fails to explain why it afforded greater weight to Dr. Patel\u2019s file review than to the reports of Ms. Rouleau\u2019s own treating physicians. In its de novo review, the Court weighs the SSA determination heavily.<\/p>\n

(2) The Court also particularly credits Ms. Rouleau\u2019s treatment records at the Pain Management Center. These records reveal a clear pattern in which Ms. Rouleau for years experienced severe pain in her back and lower extremities; received treatment that helped in the short-term; and the return of her pain. The records reflect that Ms. Rouleau continued to experience pain ranging between three and six out of ten even after the permanent implantation of the spinal cord stimulator. Her pain ebbed and flowed but was always present. Dr. Riessinger, the psychologist at the Pain Management Center, noted explicitly that Ms. Rouleau expressed eagerness to return to work and was not a malingerer.<\/p>\n

(3) The Court assigns less weight to Dr. Patel\u2019s report. Although the Sixth Circuit has stated unequivocally that there is \u201cnothing inherently objectionable about a file review by a qualified physician in the context of a benefits determination,\u201d\u00a0Calvert v. Firstar Fin., Inc.<\/em>, 409 F.3d 286, 296 (6th Cir. 2005), the court has also approved assigning more weight to evidence from a treating physician than a record reviewer who did not conduct an in-person evaluation.\u00a0See Hoover v. Provident Life & Accident Ins. Co.<\/em>, 290 F.3d 801, 806 (6th Cir. 2002) (\u201cThe evidence presented in the administrative record did not support the denial of benefits when only Provident\u2019s physicians, who had not examined Hoover, disagreed with the treating physicians.\u201d). \u201cWhether a doctor has physically examined the claimant is indeed one factor that we may consider in determining whether a plan administrator acted arbitrarily and capriciously in giving greater weight to the opinion of its consulting physician.\u201d\u00a0Kalish v. Liberty Mutual\/Liberty Life Assurance Co. of Boston<\/em>, 419 F.3d 501, 508 (6th Cir. 2005);\u00a0see also Black & Decker Disability Plan v. Nord<\/em>, 538 U.S. 822, 834 (2003) (\u201cPlan administrators, of course, may not arbitrarily refuse to credit a claimant\u2019s reliable evidence, including the opinions of a treating physician.\u201d).<\/p>\n

(4) The Court finds Ms. Rouleau\u2019s descriptions of her condition on the Activities Questionnaires she requested credible. The record reflects that Ms. Rouleau was eager to return to work. Her self-reports on Activities Questionnaires are consistent with the medical evidence. No one who treated Ms. Rouleau suggested she exaggerated her pain in any way. Her medical providers repeatedly noted her frustration with her ongoing pain and her desire to find relief.<\/p>\n

(5) Liberty points to the results of video surveillance as further evidence to support the denial of benefits. The Court views this evidence as neutral at most. It does not appear that Liberty actually relied on the surveillance evidence in making its decision to deny benefits to Ms. Rouleau at the end of the \u201cown occupation\u201d period. Liberty does not mention the surveillance in correspondence to her regarding denying her claim. Moreover, the surveillance video is consistent with Ms. Rouleau\u2019s own account of her condition. Surveillance revealed no activity at all on most of the days that surveillance took place. The surveillance activity was limited and offered little support for Liberty\u2019s position.<\/p>\n

In the video of Plaintiff unloading what appears to be groceries from her car, she moves slowly and gingerly. She takes frequent breaks. Her posture is stooped. After she bends down to reach into the car, she stands up slowly and with effort. Nothing about the video of her unloading the car suggests she can maintain even a short period of activity without frequent breaks. The surveillance company itself describes the quality of the video of Ms. Rouleau working in the area around her pool as only \u201cfair.\u201d In that video, Ms. Rouleau moves slowly and takes frequent breaks. Nothing about the video dictates the conclusion that Ms. Rouleau was capable of employment. The Court assigns no weight to the video surveillance.<\/p>\n

Noteworthy Court Comments: <\/strong>The Court discounts Dr. Patel\u2019s opinion for multiple reasons. Dr. Patel never examined Ms. Rouleau. It is undisputed that the file materials on which he based his opinion were incomplete. These materials did not include Ms. Rouleau\u2019s medical records from 2011 and did not include her self-reports on Liberty\u2019s Activities Questionnaires. The file materials Dr. Patel reviewed did not include the SSA\u2019s finding that Ms. Rouleau was totally disabled from working. Dr. Patel\u2019s report does not take into account the variable nature of pain. Nor does his report explain how he extrapolates from the limited medical evidence he reviewed that, even if Ms. Rouleau could sit for up to one hour with an option to stand, she could also do so for eight hours a day without any restrictions on her standing and walking. For all of these reasons, the Court assigns little weight to Dr. Patel\u2019s report.<\/p>\n

Summary:\u00a0<\/strong>None of Liberty\u2019s arguments persuade the Court that denying long-term disability benefits to Ms. Rouleau is appropriate. Everyone who treated Ms. Rouleau, and even Dr. Patel, who reviewed only a portion of her medical records, recognized that Ms. Rouleau objectively had health problems. Everyone recognized that her health problems made it impossible for her to care for patients directly, her \u201cown occupation.\u201d No one suggests Ms. Rouleau had any inclination to malinger or exaggerate her condition. There is a clear pattern over the years of escalating treatments required to address her pain. The SSA found Ms. Rouleau totally disabled from working. The preponderance of the evidence \u2013 indeed, the great weight of the evidence \u2013 reflects that Ms. Rouleau remained \u201cdisabled\u201d as the Policy defines it even after the expiration of the \u201cown occupation\u201d period<\/a> and is therefore entitled to the long-term disability benefits she seeks.<\/p>\n

Disclaimer: This case was not handled by disability attorney Nick A. Ortiz. The court case is summarized here to give readers a better understanding of how Federal Courts decide long-term disability ERISA claims.<\/div>\n
\n

Here is a PDF copy of the decision: Rouleau v. Liberty Life Assurance Co. of Bos<\/a><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

None of Liberty\u2019s arguments persuade the Court that denying long-term disability benefits to Ms. Rouleau is appropriate. The preponderance of the evidence \u2013 indeed, the great weight of the evidence \u2013 reflects that Ms. Rouleau remained \u201cdisabled\u201d as the Policy defines it even after the expiration of the \u201cown occupation\u201d period and is therefore entitled to the long-term disability benefits she seeks.<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_genesis_hide_title":false,"_genesis_hide_breadcrumbs":false,"_genesis_hide_singular_image":false,"_genesis_hide_footer_widgets":false,"_genesis_custom_body_class":"","_genesis_custom_post_class":"","_genesis_layout":"","footnotes":""},"categories":[1],"tags":[246],"_links":{"self":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts\/7577"}],"collection":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/comments?post=7577"}],"version-history":[{"count":0,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/posts\/7577\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/media?parent=7577"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/categories?post=7577"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.nickortizlaw.com\/wp-json\/wp\/v2\/tags?post=7577"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}