When I use the code below, it works...but as soon as I change the note from"ERRPYO002" to anything (eg: "thanks for your help"), I get a 

MALFORMED_REQUEST_ERROR error: "Json request malformed".  Google searches show that only a handful of other people get this error, and there is no help to be found.  It makes zero sense that the string in the "note" field has to be exactly "ERRPYO002".

Also, it seems that no one from paypal ever answers any questions here.  I've seen forum posts where people ask if anyone ever helps with questions and it seems like the answer is no.

Is there some magic thing we're supposed to do to get developer support?  Or is paypal pretty much saying "Good luck. You're on your own"?

curl -X POST https://api.sandbox.paypal.com/v1/payments/payouts \
-H "Content-Type: application/json" \
-H "Authorization: Bearer [THISISMYACCESSTOKEN]" \
-d '{
"sender_payout_header": {
"sender_batch_id": "1524086406556",
"email_subject": "This email is related to simulation"
},
"items": [
{
"recipient_type": "EMAIL",
"receiver": "[EMAILADDRESS]",
"note": "ERRPYO002",
"sender_item_id": "15240864065560",
"amount":
{
"currency": "USD",
"value": "1.00"
}
}
]
}'