I do not work and not able to work because I was injured at work and now suffer depression, anxiety and PTSS  after being harassed, bullied, and made to carry out excessive work for 5 years in an a toxic office environment working as a professional building regulator and certifier.; I had been on workers compensation payment until the insurance company stopped the payment 18 months ago; I received the letter below from my lawyer which the insurance company sent to them, requesting that I provide them the information in regards to items 1 to 10.;  can you advise what my legal requirements are and how I should response to this letter and prepare a response for me: 
{StateCover Mutual Limited
ABN 36 090 394 755
PO Box R1865
ROYAL EXCHANGE NSW 1225
www.statecover.com.au T (02) 8235 2800
F (02) 8004 8253
E <PRESIDIO_ANONYMIZED_EMAIL_ADDRESS>


27/04/2023

Longton Compensation Lawyers Attn: Toya Kha
Sent by email to: <PRESIDIO_ANONYMIZED_EMAIL_ADDRESS>

Without Prejudice

Dear Toya

Claimant:	Rocco Verrelli
Council:	Georges River Council
Claim No:	C21/43505
Your ref:	700264

Request for particulars
We confirm that by letter to us dated 13 April 2023 you served a report of Dr Richa Rastogi dated 19 October 2022, and asserted a section 66 claim for 19% WPI.
We advise that we require further particulars regarding your client’s claim.
Sections 281 and 282 of the Workplace Injury Management & Workers Compensation Act 1998 and confirm that the 2 month period referred to in section 281 does not commence until all relevant particulars have been provided to the insurer.
Accordingly, we have arranged an independent medical examination for Mr Verrelli and will advise details under separate cover. This referral is made in accordance with SIRA's Guidelines to enable a proper assessment of your client’s full entitlement to permanent impairment compensation.
We also request that you provide the following further and better particulars of this claim within 14 days:
1.	Has your client engaged in any form of paid employment or self-employment since 21 December 2020? If so, please indicate/provide:
a.	The names and addresses of all employers, including self-employment.
b.	The period of employment in each job and the hours worked during an average week and the maximum hours worked during any week in each job (including self- employment or voluntary work).
c.	The capacity your client worked in, in each job, including details of your client’s employment classification and a full description of all duties performed.
d.	Copies of all group certificates/PAYG summaries and pay slips held by your client in respect of each job held since 21 December 2020.
e.	Your client’s reason for leaving each job and the date of resignation/termination in each case and a copy of each letter of termination or letter of resignation (if applicable).

2.	Please provide copies of all tax returns and notices of assessment in respect of your client’s personal income and copies of any business tax returns and notices of assessment in respect of any businesses they have traded in, for each financial year from 2020 to date.
3.	Has your client suffered from any injury or disability apart from the injury/injuries alleged against our client? If so, please provide:
a.	Details of each injury and disability including when it occurred, how it occurred and what body parts were affected.
b.	Details of all claims for compensation or damages made including the date of claim, who the claim was made against, whether it was litigated and the outcome of the claim, including details of all compensation or damages received.
c.	In relation to all prior and subsequent psychological conditions or episodes mental illness (excluding the injury alleged against this employer), please outline the dates and circumstances in which each such injury, condition or episode of mental illness occurred, the names and addresses of any doctors, hospitals, counsellors, psychologists, psychiatrists or medical providers who provided treatment, the nature and frequency of the treatment received and the period of treatment and the degree and duration of symptoms, disabilities and restrictions that followed from each such injury, condition or episode.
4.	Please provide details of the names and addresses of the worker’s usual treating general practitioners in the periods from 2017, including the approximate periods over which each GP or medical centre was their usual treating general practitioner.
5.	Please provide full details of any educational study or programs undertaken by your client since 21 December 2020, including the name of the course, the qualification they were studying for, the name and address of the institution they studied at and the start date and the end date of the course and full details of any qualifications or certificates obtained as a result of any such education or study course.
6.	Please forward copies of all academic results notices and course diplomas or degrees or award certificates obtained by your client in respect of the years from 21 December 2020 to date during any such years when they were enrolled in any course of study at a school, TAFE college, other college or university.
7.	We enclose authorities addressed to:
•	Marinucci Medical Centre
•	Specialist Medical Centre Lithgow Community Hospital
•	St John of God Medical Centre
•	Healthemind Clinic
•	The Bankstown Clinic
•	Dr Anthony Pignataro
Please arrange for your client to sign these authorities and return them to us so we can obtain the medical records from doctors and/or medical centres who have treated your client in the past.
8.	Please provide the details of all travel undertaken by your client outside Wareemba since 21 December 2020 including the dates over which each episode of travel took place, the
locations or destinations your client travelled to in each case, the person or persons travelled with in the case of each trip and a brief summary of their activities during each such trip or holiday.
9.	Please provide copies of all stamped pages of your client’s passport which contain travel stamps post-dating 21 December 2020 together with a copy of the front photograph/identification page of their current passport or of any passport that has been valid since 21 December 2020.
10.	Please provide us with the letter of instruction and all attachments sent to Dr Rastogi in preparation of the report dated 19 October 2022.
The above requests are relevant to the PIRS categories of employability, travel, social functioning, and concentration, persistence and pace. Some are also relevant to the issue of whether a deductible proportion of may be applicable under section 323 of the 1998 Act in respect of any prior injury or pre-existing condition.
We request that you please provide the further and better particulars and documents and authorities requested above within 14 days.
In the interim, we seek your advice regarding any amounts owing to Medicare Australia which relate to medical services your client may have claimed for this injury. Please have your client complete a Section 23A Statement and Statutory Declaration AND an Authority to Release Information and return them to us as soon as possible.
Please note that failure to respond or properly advise us regarding Medicare as above could delay payment of the lump sum.
If you have any questions, you can contact me on (02) 8235 2800 or by email at <PRESIDIO_ANONYMIZED_EMAIL_ADDRESS>.
Yours sincerely

<PRESIDIO_ANONYMIZED_PERSON>
For Elizabeth Bowley
Case Manager}