Complaint about barrister Ken Pryde

I submitted a complaint about Ken Pryde actions, reference number CAS012566. I got a response that OLSC will not investigate my complaint and if I understand correctly the core reason was that most of the complaint focused on Potts actions. This was so because I wrote it as one story as they worked together. I had more documents relating to Potts actions rather than Pryde, so Potts was mentioned more often. However, when it comes to communications Pryde was way more verbally abusive than Potts (Potts complaint reference is CAS012565). I believe Pryde acted unfairly in his own interests, completely breaking the whole foundations of the legal system.

In this document I write about Pryde actions and the reasons for late submission and I hope it will give enough reason to change your decision and investigate Pryde actions.

Ken Pryde was meant to assist me with my claim. Instead he ran a scam together with Potts, damaged my claim, manipulated and abused me and left me in a situation where I had to endure a lot of unnecessary pain and suffering, had to engage other lawyers and spend a lot of energy trying to fix my claim (this resulting in significant financial loss that is yet to be determined). Pryde's actions worsened my PTSD symptoms and it is a very long road in trying to heal. Unfortunately, the same PTSD prevented me from writing this complaint any earlier than I did.

In my complaint application “3. How do you want us to help you to resolve your complaint?” I accidently included two parts of actions I was meant to include only one (part B) that is about Ken Pryde.

For 3 years I was trying to find out what to do about Ken Pryde and Gillian Potts actions. With the help of lifeline (I think now there would be more than 400 calls to help lines) I thought I found a solution and prepared a complaint and I thought I did it on time. It would be fair and just to accept my complaint about Ken Pryde even if it is beyond 3 years time limit.

Reasons for late submission

The main and basically the only reason for late submission is the PTSD that I have as a result of road traffic injury on 2015-03-30. PTSD is a very debilitating disability that in my case severely limits my cognitive abilities and makes it close to impossible to take some actions. It is very difficult to gather, understand and retain information, especially when it is related to the injury as memories and thoughts get blocked and I am constantly exhausted.

Some of the information about PTSD effects that allowed Pryde to abuse me the way he did and made it so difficult to write this complaint I already wrote in complaint, especially in sections “Impact on mental health” and “How I got into this mess”. I also included some of the medical reports about my disability. I am including further medical reports and I wrote a more detailed description of its impact in the document: 2023-07-17 Reasons for late submission of complaint.pdf. Consulting psychiatrists and psychologists say that even these complaints are big achievements given the circumstances.I believe my disability is a valid reason to give me a time extension as. I did all I could to understand my situation and submit this complaint as soon as possible given my mental health problems.

Non medical reasons for delays were that my claim is still ongoing and some of the outcomes can be used as proof, like medical assessments (has been updated fixing some problems caused by Pryde and Potts), but some decisions are still in the future. The PIC assessment conference occurred 2023-06-28, the decision is still pending.

I also got access to my file only very recently 2023-05-11. If some of Potts and Pryde actions were past the 3 years deadline please consider extending it as despite my illness I did all that is in my power to meet it.

Short description

1. Ken Pryde was an active partner of Gillian Potts in mishandling my claim, inflating legal fees, almost taking away my chances to get any fair compensation and causing a lot of stress.

2. Pryde advised that due legal constraints I can not mention PTSD in my claim (arguing that PTSD can not be used for road traffic injuries) and made sure that it is not mentioned in my statement. While PTSD was diagnosed and confirmed by every treating specialist.

3. Pryde insisted on providing less information about my mental health problems (including PTSD). This resulted in CARS assessment that did not provide any compensation for non economic loss (see 2019-09-16 Matthew Jones Assessment.pdf ).

4. Replacing PTSD with depression significantly reduced the degree of impairment for my claim and opened the opportunity for insurance (QBE) to argue that it is a repeat of my depression from

2011/2012. This is a very different illness with very different severity and helped only QBE to argue against severity of impact of road traffic injury. During depression in 2011 my functioning was hardly impacted (I was self sufficient, social, active, went traveling and soon recovered), while after the injury while affected by PTSD it basically stopped. Without PTSD QBE speculated that I may have had depression before the injury, contradictory to evidence.

5. Pryde said that he had a deal to keep my mental health impairment below threshold and that explains his actions.

6. Pryde not only inflated his own fees but helped Potts to inflate Lawpartners fees as well (for example fake settlement conferences).

7. Pryde provided assistance in running a scam by confirming and even more often putting forward actions and misinformation about law.

8. Pryde defended the interest of the insurer (QBE) at my expense defending the fraudulent report from QBE.

9. Pryde applied enormous emotional pressure and verbal abuse in order to manipulate me to accept the settlement that was not in my interests (especially phone conversation with Pryde on 2020-05-06). 10. Pryde and Potts put me through additional stress for 2 years and made me lose faith in the legal system.

11. Pryde caused long lasting emotional suffering that significantly amplified my PTSD symptoms and is causing problems up till this day. I still can hear him saying that no one is going to believe and any action I will take regarding my claim and things related to it will make the situation worse.

12. As a result I strongly believe that my claim would have been better if Pryde would never have gotten involved.

13. My mental condition prevented me from realizing what was happening and taking any actions to fix it. I asked to stick with the plan of going to government authority to determine the outcome of the case. Pryde told me that they will never allow my claim to be seen by an independent assessor and threatened me from seeking a second opinion. That if I do this their fees will go up significantly.

14. After splitting with Lawpartners it took me a lot of effort to get my mental health impairment recognized (see 2021-03-17 Wayne Mason assessment.pdf ), but I still do not have a final result for the compensation claim.

15. The horrible part is that Pryde knew how vulnerable I am, that his actions are going to cause terrible suffering for me and did it anyway, just to get some unfair gain without any regard to consequences on my wellbeing. And it worked, I got so affected that I was not able to get any justice so far. He must have a lot of experience in this.

Pryde’s actions

Some of the information was provided in the original complaint, however, I added a lot of new information only about Pryde actions and removed some what was only about Potts.

I got injured in a road traffic injury on 2015-03-30. Solicitor Gillian Potts together with barrister Ken Pryde represented me for a personal injury claim from March 2018 to June/July 2020. Their legal representation best can be described as a scam. They grossly overcharged me, provided misleading advice, acted against my instructions under pretense that this is a law, manipulated me and took advantage of my illness. They lied about costs and presented me with grossly inflated costs to prevent me from accessing the legal process for my personal injury claim. While many actions of G. Potts and Ken Pryde were at least dishonest and I believe illegal, when put together they come up in one big scam (see 2023-06-07 Lawpartners scam.pdf for more details about their scam), that was run purposely from the start.

In order for lawyers to represent me I had to supply all information about the effects of injury on my physical and mental health. My main problem is PTSD. It makes it almost impossible to deal anything related to injury as any mention of it triggers flight, fight, freeze or fawn (to agree with everything to avoid the perceived threat) response. Mostly it is freeze or fawn response - very disrupting as it shutdowns my ability to think or take any action. I can not function in any face to face appointments including assessments that were so important for my claim. Instead of using this information to form the basis of my claim, Potts and Pryde used it to spend time on activities that did not benefit my claim in any way, just created a lot of stress for me.

At the end I am left in a situation where my claim is way much worse compared to where I have started with G. Potts or Pryde.

1. Validation of LawPartners scam. I think the Lawpartners included Pryde as a partner to run their scam. LawPartners never intended to represent me properly and have my claim assessed (see 2023-06-07 Lawpartners scam.pdf). In order to show more legitimacy Potts needed a partner who fully supported the scam and provided the impression of independent confirmation of fake statements. Pryde did exactly that and even took a leading role during meetings by stating fake information first, putting pressure and dragging time. Pryde was also a key in exaggerating the legal fees.

2. From the beginning Potts and Pryde provided some information only verbally. At that time it looked very strange. Now looking back it makes sense. I provide information as accurately as I can even if there were parts that I may not be able to prove.

3. Fake inclusion of barrister. Potts told me that a barrister will be needed only if my claim goes to court. However, she sent me barrister Ken Pryde cost agreement dated 2018-05-29. I have never signed it (see 2018-05-29 Ken Pryde cost agreement.pdf ), because I thought it was still far away and I thought he was overpriced. However, during the next meeting with Potts Pryde was also there. Potts told me that my claim can not go forward without initial consultation with the barrister. That was in contradiction to what Potts told me before.

4. Getting locked with LawPartners and Pryde. Because of some delays with my claim I felt that I am locked in with Gillian Potts from LawPartners. So, when she introduced Ken Pryde despite me not agreeing on it I felt I had no choice otherwise I would lose my claim. Only when I moved to a different solicitor I found out that I had a right to change lawyers without losing my claim.

5. I first met Ken Pryde on 2018-06-12 (from the emails). I told Pryde about my difficulties to collect and process information and that any stress triggers me to go into a panic attack, then my head shuts down, I go into autopilot mode and then I would do anything just to get out of the situation. This was one of the PTSD symptoms that was making my life very difficult. Pryde was making long half jokes about unrelated things and I tried to bring him back to the subject - my claim and asking questions about it. Instead of answers I got verbal abuse asking why I was so stupid to ride a bicycle, that I deserved to be hit and should not complain about it. It triggered such a strong panic attack that I ended up leaving the meeting in search of a toilet to puke. When I came back Pryde told me that he wanted to see how I would do if questioned as a witness and he was happy about it, but I should not ever interrupt him again.

6. After this experience I asked Juste (my future wife) to join me during the next few meetings. However, it did not help much as Pryde was still dragging time and not providing any useful information (see 2023-07-17 Juste Stoniene. Statement re Kent Pryde.pdf). With exception of Juste's statement there was only one time Pryde asked (and Potts repeated) something related to injury. Pryde asked if maybe she could influence me to give up my interests and accept their view. While making it obvious that she found it insulting Juste replied, that when she met me, she learned that I have strong principles and I seek my goals, that even while ill now deep down I know what I want and she respects it. She told me that she is here to support and not to make me feel worse. For the next meeting I was told that it is not necessary to invite Juste (I can not remember what the reason was, but it sounded like a fake one).

7. Lying about process and costs. Pryde told me that the fees amount to something around $25,000 if the claim goes to court. However, if it is decided by a tribunal it should cost about $12,500. This later turned out to be false.

8. Pointless meetings with a barrister. With the exception of the statements that could have been done way more efficiently by email there was no need to meet the barrister. That was simply a duplication of the work. So, Potts would spend most of the meetings doing other things, for example browsing something on her phone or reading documents, that were not related to my claim (I had a peek).

9. I understood that this was a plan to inflate fees only after a few years. Potts promised that fees will be low, that even in the worse case scenario fees will be no more than 30%. However, barrister fees were not included in this limit. So, Potts introduced the barrister to inflate their fees.

10. Pryde prepared my statement skipping evidence of my ability to work before the injury, making it look that I was more capable to work after the injury and refusing to mention PTSD anywhere in my

statement (details below). All this was used by QBE to present that injury had minimal effect and reduce potential compensation.

11. Refusal to mention PTSD. Both Gillian Potts and Ken Pryde were strongly against PTSD being mentioned in my statement of 2019-04-29. They told me that there were legal restrictions and I could not use it. Despite PTSD being diagnosed by Joyce Chiu (see 2015-11-02 Psychological/Counseling Management Plan) and confirmed by Mulet (see 2017.10.23 EloisaMuletNotes.pdf ) and Steve Sutton (see 2019-11-16 Stephen Sutton Report.pdf ). They told me that they have many years of experience and that is their legal advice. Pryde even called me in the evening not to “tinker” with the statement and to return it signed, but otherwise unchanged without giving me a chance to read it or to process it. It felt unfair for me as PTSD was my main problem and I would rather use the name of the illness instead of listing its symptoms. However, I could not argue as I did not know legal requirements. I provide my recent statement for comparison when I was not restricted by solicitor to remove any information about PTSD symptoms (see 2023-04-26 Alfonsas Stonis further statement.pdf ).

12. Failure to include information that was very important about my functioning before the injury. Even being rushed I have provided a lot of information about the project I have been working on before the injury (see 2019-04-23 email to Potts - The application I was working on before the incident.pdf ,

2019-04-23 contacts_task_application.pdf ). However, G. Potts with K. Pryde reduced it to one item number 31 in a statement on 2019-04-29. They insisted that this is enough.

This was not enough. It did not reflect the amount of effort I put in nor my capacity to work. As a result it left room for speculation by QBE. This left damage on my claim when based on incorrect information from QBE and lack of correct one from my solicitors lead to error in assessment of my functioning prior injury. This significantly reduced my chances to get proper compensation.

For example, about my same topic, I wrote items 58, 63-69 in a new statement provided on 2023-04-26 and provided several supporting documents under the guidance of a current solicitor.

13. I have strange glitches in my perception of information when I miss some information entirely. Often it can be explained by stress. However, sometimes I have no obvious cause for stress. I was suggested by a few psychologists to speak to a GP and maybe see consultation with a neurologist as the symptoms can also be explained by brain damage. I strongly hoped that I did not, but maybe it was a good idea to rule it out. I mentioned it to Pryde as he asked how my treatment is going. Pryde was strongly against it. He said that if QBE finds out that I even mentioned it to GP asking for her opinion it will be treated as an attempt to inflate payout and I will lose my claim completely. He told a very long story about his chemistry teacher elaborating on all his features, who told Pryde that even metals evaporate, just very slowly. Then Pryde asked if his old rusting can evaporate in a few years, but the teacher replied that it will take much longer. So, Pryde told me that his car has a better chance to evaporate than me having any other problem than depression. He told me to restrain from any other treatment till the claim finalizes.

14. Secret agreement on mental health assessment. Mathew Jones' assessment was very incorrect and I was trying hard to understand how this could happen. Unfortunately, I do not have proof of this as it was told to me only in person. However, after hearing it, many actions of G. Potts and K. Pryde starts making sense. After I got an assessment by Jones , I wrote to G. Potts a list of lots of errors in assessment and asked to request a review of assessment. When I met them G. Potts and K. Pryde’s response was that they were not going to do it: the assessment is exactly as they have agreed and complaining about this assessment will break their agreement and they will not be able to get favors for the next client. They told me that I will get enough compensation anyway and another client may not be in such a good position. They have not specified whom they agreed with, but I assume it could be QBE lawyer and/or assessor Jones. This explains why they refused to get a report from Steve Sutton, and why they have been so negligent preparing documentation for assessment. They have refused to seek review of assessment.

I know it is only one remark that I can not even prove. However, I thought I would mention it for completeness.

Lucky after I changed solicitors and Jones' assessment was replaced (see

2021-03-17 Wayne Mason assessment.pdf ).

15. Incorrect complaint about assessment. I was insisting on a request for a review of Jones' assessment. Surprisingly G. Potts wrote “there are grounds to seek a Review of the MAS assessment” (see 2019-10-24 Gillian Potts - Assessment appeal dead line.pdf ). Next day Pryde called me and told me that this was a typo and they meant “there are no grounds”. However, I insisted on appeal and this was probably the only time they followed my instructions (see

2019-10-30 LawPartners MAS form 5A.pdf , 2019-10-30 Claimants submissions for MAS 5A.pdf ). The request for review was denied and G. Potts told me that there is nothing I can do further. Later I found out that request was denied because it did not include required information, something that I believe could have been fixed (see 2019-12-16 Statement of Reasons.pdf ). Two years later when QBE made similar requests for review of Wayne Mason assessment and when they were denied, QBE submitted requests few times till they were granted. It seems that this is another example when Potts provided me with false information about law and procedures.

16. Intentional draging of time during meetings. G. Potts and K. Pryde had an attitude towards meeting that can be only explained by intentionally dragging time. They were late every time, from 10 to 60 minutes. Pryde usually would come first, but then I would need to wait for Potts to come. Usually another 10-15 minutes. Then they would tell me that they need to discuss another case. I would be invited to join maybe another 15 minutes later. Then Potts and Pryde would discuss the weather and unrelated subjects for a few more minutes. My attempts to come to the subject come to nothing as Pryde would interrupt me every time and continue on unrelated subjects. On the first (June 2018) meeting Pryde got angry that I kept trying to bring back to my case. He started asking aggressive questions, like “how come you were not able to avoid the car hitting you?”, “don’t you know that cars are dangerous?”, “anyone else would get better by now, why not you?”. It triggered such a strong panic attack, that I could no longer understand what they were saying and had to rush out and look for toiled. Later, Pryde said that maybe he was too aggressive and that this was the first time he managed to force someone to vomit. In time trying to bring them back to the subject became too triggering and I had to endure empty talks. I remember that one time after Pryde's very long talk about nothing Potts nodded smiling that Pryde has skill to talk. Meetings in 2020 were even worse.

17. Dragging of time for the whole claim. My claim had many delays that were not explained. One of the ways to drag it was appointments with Pryde where nothing has happened and a tiny bit of information could have been easily passed by email. The most painful ones were probably the delays for fake negotiations (listed in bill) when there was nothing to discuss and I was called under the pretense of submitting documents to PIC.

18. Lying about requirements to settle. After failing to get PTSD recognized as having an impact on my life, Potts told me that this is a good time to submit documents to CARs for assessment of loss of potential income. However, before doing this we are required by law to attempt to settle. When I came to the so-called settlement conference on 2019-10-20 it started the same way as every meeting with Pryde and Potts. Half an hour wait till Pryde and Potts came. Then we went to Pryde's office. They told me that they were going to negotiate now and we have to wait there. My wife and I were shocked. I was told that it is important that my wife accompanies me during negotiations as it may be stressful. I told them that I want to participate in negotiations, this is the only reason I came. I was told that due to procedural requirements they do not allow it. I asked them if I could at least meet them, so that I can put the face behind the name. They told me that they do not allow clients to meet insurance representatives. Just a few minutes later Pryde came back and told us that negotiations were not successful and we need to wait for Gilian. When Gilian comes back several minutes later and says that they have not spoken about the claim after Pryde left, only catching up on what is new in their lives. Pryde told me that QBE offered compensation only for future loss, max $250k and he instead asked for $800k. QBE refused to negotiate. For Pryde it was not acceptable. I was told that there is nothing to do now for me. They will prepare and submit documents to CARs as QBE was not being reasonable. Up till this day I do not know if there was actually a meeting, it had no purpose, simple exchange of emails would have been enough, also my wifes and my participation was completely pointless.

19. Fake negotiations. Next time I was invited to meet they went for the new record of how long I had to wait. I think I waited more than an hour before someone showed up. I was under the impression that I 5

needed to sign some papers for CARs application. Instead I was asked what sum I would be prepared to settle. I was not prepared for this. They told me that they were required by law to make another attempt to settle. I gave sum, something similar they have been talking about as a good result before. I was told that their fees were something about $50k and what I would get after subtracting medicare and centrelink. They have asked me to leave while they make a phone call. Again did not let me even hear what they were talking about. Few minutes later they asked me back into the room and told me that negotiations were not successful, but they were required to do this by law. This time I already got angry as I have seen this meeting as pointless. I have asked them to stop ambushing me with such a request to settle and to submit CARs application. They told me that they can not do it now because there is a request from QBE to have another assessment.

It might seem strange how I could be manipulated so much, why I did not protest. The answer is simple: they told me that they know what they are doing, that this is required in my case and I have to do what they were telling me. They played on my fears, telling me that this is a very unfair system and they were doing all that is possible to help me.

There was no real new information between these fake negotiations, they did no preparations, no new information passed to me. Just complete fake to extract money under false pretense.

20. Another example of fake negotiations. Melissa sent me an email inviting to meeting on 2020-01-09 (see 2020-01-09 email from Melissa - Next meeting 29th 15 00.pdf ). She did not provide any information for the reason to meet. Because I previously did not agree to the offer and asked to submit an application for an independent assessment I thought I needed to sign some papers for it or something like that. Meeting goes the same way, Pryde comes late more than half an hour, but he says he is busy with other things. We have to wait another half an hour for Potts to come. When the meeting starts I ask was the application submitted? Pryde asks if I mind if they make a call first to QBE. I agree. Maybe a minute later they ask me back and say that QBE offered $225,000 (of maybe $2000 or $3000 less). Do I agree? I say no, I want my claim to be assessed by an independent assessor. They ask me to think about it and if I do not agree they have no chance but submit the application for assessment. Later I get an email with offer after fake conferences: $225,000 total, $92,000 after deductions on 2020-01-29 (see 2020-01-30 email from Potts offer - YOUR MOTOR ACCIDENT CLAIM.pdf ). I do not agree on this and yet they do not submit the application.

21. Lies about Moodley assessment before it. In a meeting on 2020-01-29 with Pryde and Potts was told that there will be an assessment by a psychologist hired by QBE. I was worried that a specialist hired by QBE might be not objective and might twist things in favor of QBE. Pryde told me not to worry and that there is one important thing he wanted to say to me about this assessment. Then he made a very long pause. Pause was so long that Potts started browsing something on her phone. Then Pryde finally added “this is all I want to say”. Potts nodded with a wide happy smile, while looking at my frustrated face. I asked what he meant. Pryde reiterated that this assessment is by a psychologist and made another long pause. I can imagine bad advice, but this was a new low. There was no point taking more abuse, so I have not repeated my question again.

It turned out that Moodley had no intention even to pretend to be even remotely objective. We counted 146 factual errors in that report (see 2020-03-18 Moodley report errors.pdf ). She wrote the whole assessment based on fictional events. Warning to be emotionally cautious would have saved me from a lot of suffering. Warnings about the process would have been useful too, like that I can ask for a break during the interview as I have continued it despite being very tired and badly needing a break. There is a strong chance that it would have saved me from some incorrect statements from Moodley.

22. Lies about Moodley assessment impact and my options to complain about it. When Potts told me that she got a report from Moodley at the same time I got a notice from the GP that there is an important report ready and I should make an appointment to discuss it (see

2020-04-29 email from Gillian Potts YOUR MOTOR ACCIDENT CLAIM.pdf ). Potts was reluctant to send me Moodleys report but when I told her that I am going to get it from my GP anyway she sent it to me. It turned out that the GP was talking about a report from a cardiologist that I forgot about. It was a shock to me. I expected to be mostly objective (Moodley fooled me well). While it had incorrect statements almost in every paragraph (146 errors in total 2020-03-18 Moodley report errors.pdf ), twisting the whole story upside down. It only proves how easy I am to manipulate as I believed her

when she was assuring me that she will write the truth. However, her statements could not be true as they conflicted with each other, time scale and location.

For example she was saying that was so depressed before the injury that my wife had to make me lunch before going to work, or I would not eat. The problem is that I was not married at that time and Justė whom I married later was still living in Lithuania.

Another example: Moodley wrote that the next relationship was with Russian women in 2011, continued for 2 years and caused my depression to get worse. And because of the relationship breakdown (that would be 2013 according to Moodley) caused me to get depressed in 2011. Not true. So many things wrong. Our relationship started in 2009, I was working full time, was not depressed and it was good at the start. BTW splitting was a good thing as it was not working. There were many more time inconsistencies that continued all through the report. For me it looked more like a student who is learning a new foreign language and got a task to invert every sentence.

As it was very PTSD symptoms triggering to see my life story so twisted in the time given I wrote to them only about some errors in the Moodley report. However, it was enough to dispute this report's conclusions. To my shock Potts and Pryde were fine with Moodleys report. They told me that it does not matter even if she got every sentence wrong. It will be discarded as minor problems. The main thing for them was that she wrote that in her opinion I am absolutely fine and only pretending to be impacted by trauma. Pryde told me that no one will ever believe me now and that my mental health problems will never be recognized in one of the late phone calls with Potts and Pryde. I asked Potts to ask for notes from the interview for assessment as I remember that at least for one test I wrote answers with my hand and Moodley after checking them told me that I did not show any problems with my basic functioning. While in her report Moodley wrote that I was faking the test. Instead, Pryde called me and threatened that I will get nothing if I request for notes, it will only damage my claim and this request is against their advice and therefore I will be breaking the contract. Scared from their threats I withdraw my request for notes (see 2020-05-06 email from Potts further pushing me settling threatening with Moodley rep… ). The report stayed and damaged my claim. It might have been very different if I asked for data to prove that there were errors in tests too.

23. The only reason I can think of why Moodley wrote such absurd things in her report is that she knew that LawPartners would not dispute it. I can not explain it otherwise. Pryde defended Moodley as a very respected expert. However, latter I found that she has reputation of providing false reports and in all 3 occurrences on Personal Injury Commission database her reports been ignored (see https://pi.nsw.gov.au/__data/assets/pdf_file/0004/470488/7185-07-STARR-MAP.pdf https://pi.nsw.gov.au/__data/assets/pdf_file/0004/470488/7185-07-STARR-MAP.pdf https://pi.nsw.gov.au/__data/assets/pdf_file/0012/953769/2979-20-Doulman-MAP.pdf). She also was ignored by PIC assessors in my case and the PIC decision maker in tribunal told that tests she performed are not recognized by courts.

24. Pryde used this report to apply further psychological pressure to settle and went very hard defending Moodley. I asked Lawpartners to ask Moodley to provide raw data from tests as I wrote few with my hand it was not what she wrote in the report. Instead Pryde called me and applied emotional pressure threatening all sorts of problems that I finally give in and revoke my request for raw data (see 2020-05-08 email to Potts - About asking for row data of test for Moodley assessment.pdf ).

25. Refusal to submit my claim to an independent assessor CARS. From the start Pryde assured me that if I am not happy with the offer from QBE I can go to an independent assessor and geet assessment that QBE must accept. However, later he changed his story saying that he will charge extra if I try to do it and at the end that he will not allow it at all.

26. One of the most abusive calls was on 2020-05-06. This conversation with Pryde caused me a lot of stress. Just trying to remember it creates so much stress that I can not cope with it. So, previously I provided only a short description focusing on the facts that were related to other Pryde actions and avoided telling emotional abuse that took place.

Potts arranged a Zoom call with Pryde and me. The goal was to discuss the Moodley report and further actions (because last time I asked to submit documents to the tribunal and I was hoping it would go ahead).

The call was meant to start at 14:00. I think that was the first time they tried Zoom (beginning of pandemics) and they had technical issues, especially Pryde. Pryde was complaining that he could not properly hear Potts. They tried reloading to the conference several times and played with their equipment, but could not solve their technical problems.

At the end Pryde made a telephone conference and launched a brutal attack on me. He told me that everyone will believe only Moodley statement that I was so depressed before the injury that Juste had to make food for me before going to work, that after injury I fully recovered from my depression. He said that many factual errors in the Moodley report is a minor thing and he will not do anything about it. He made it sound that it was my fault that Moodley wrote so many lies in her report. I asked Pryde what about other reports that conflict with the Moodley report. Pryde told me that Moodley has an excellent reputation and no matter how many reports I have or even if I go to another 10 assessments the Moodley report will be the only one that will be looked at. No tribunal or any judge will give me anything. If I try I will have to pay not only their legal fees but also for QBE. Moodley detected that I was severely dysfunctional before the injury and after it I got much better. Pryde insisted that the Moodley tests are recognized by courts as hard core evidence. Pryde told me that Potts' friendly relationship with Ceballos is the only reason QBE is offering something. Pryde demanded me to accept the offer instantly without thinking about it. He said that I should take money and run as a scumbag like me does not deserve it. Their explanation contradicted previous statements and did not make sense. I told Pryde that I would like a second opinion. Pryde pretended that he did not hear.

Panicking and not being able to think I actually repeated it maybe seven times. Pryde every time pretended that he did not hear me (he was already laughing at me). Then I realized that he is against me talking to any solicitor and I whispered that I want to talk to my wife. Pryde told me to do so. This injustice was so triggering that I went into a severe panic attack, just managed to say that I need time to think and can not talk anymore. I was physically incapable of making any decision that day. During this conversation I was having very strong panic attacks. Because I was not able to listen and to talk I asked to take a break.

The breaks were for about an hour or so. I called one distant relative who is a solicitor but works in a different field. He helped me to calm down a bit. During the last conversation Pryde demanded to accept the offer. I tried to explain that I am panicking and so overwhelmed that all I can think is “I want to die”. Pryde said that then I should do that instead of trying to extract money from QBE. I wanted to say that I am not suicidal, I will am not going to do it, but become to nauseous and ended conversation for a day. After this just mentioning Lawpartner and especially Pryde is causing me panic attacks.

This made it difficult to write a complaint about them and I still can not go into too much into details.

27. Pryde wrote that I have an attitude problem after verbally assaulting me. Usually Pryde was very careful what he is writing but in the last his advice on 2020-05-06 he wrote setting Moodley report as truthful, completely discarded all my notes about factual errors called me having difficult attitude for not agree with him after lengthy verbal abuse (see

2020-05-06 Letter (Advice) - from counsel confirming discussions with client re Ms Moodley's rep… ).

28. Gross exaggeration of costs. Pryde said at the beginning that the cost will be about $25,000 if going to court and about half of that if the claim is finalized by tribunal or settlement. In his cost agreement he wrote $20,000 including one day hearing. However, he provided a bill for more than $25,000 without any result being reached (see cost agreement and bills).

29. In summary Pryde produced only 3 actual documents:

\* 2019-04-29 Alfonsas Stonis and Juste Stoniene statements - had huge intentional flaws (crucial removing PTSD) and would be better written without Pryde influence.

\* 2019-10-30 Claimants submissions for MAS 5A.pdf - did not meet requirements and was dismissed.

This did not help claim in any way and required a lot of effort to fix it.

30. Threats to damage my claim. Pryde, with Potts agreeing, told me that they will prevent me from going to PIC for assessment (tribunal). They also told me that I will not be able to continue my claim with another lawyer. I have contacted solicitor Moya de Luca-Leonar for a second opinion and she offered to take my case in June 2020. De Luca contacted Potts asking for a file. Potts requested to agree with 8

exaggerated costs removing the 30% cap before agreeing to pass the file (see

2020-07-17 Tripartite Deed.pdf ). I did not agree with such gross overcharge. I was left without a LawPartners file. However, when I got it, I saw that they basically have not done any preparations for my claim anyway.

31. Put psychological pressure that no one is going to believe me. Starting from November 2020 Potts and Pryde started telling me that the personal injury claims system is very unfair and I am at risk that no one is going to believe me. Early March it got more intense when they started pushing me to accept the QBE offer. After the fraudulent Moodley report, Potts and especially Pryde started calling me all sorts of names like useless, good for nothing, worthless weakling, who tries to profit from an honest insurance

company. It got even worse in May. For example I asked for time to think and got a reply pressuring me to settle urgently (see 2020-06-02 email from Potts presure to settle in reply for a time to think.pdf ). As sad as it sounds, Pryde's words that no one is going to believe me stuck in my mind for a long time.

32. I wrote a short summary of “Impact on mental health” in my complaint. The quotes given there is what Pryde told me. The level of degree of abuse and betrayal by Pryde was so high, that even now just mentioning his name or events that happened triggers PTSD responses.

33. Till I got PTSD I had no clue how debilitating this illness is. It consumes all my life, I can not sleep, work, relax or enjoy anything. And Ken Pryde made it worse. The driver who hit me even if he did it on purpose (as he claimed) made a bad decision at that moment. I do not think he planned it. However, Pryde planned and executed it on purpose, together with his partner Potts. I do believe such people should be in jail. The irony is that compared to my current life, jail looks like holidays. The last four years were worse than being in jail (even if I have no experience with it).

Telling my story

I wrote short summary about emotional impact of Ken Pryde actions (most of the time I wrote LawPartners as from emotional impact there were two equal scamming partners: Potts and Pryde) and difficulties writing this complaint in the original complaint documents and in explanation for late submission 2023-07-17 Reasons for late submission of complaint.pdf.

While I received a lot of help from many people, a huge contribution comes from my wife Juste Stoniene who helped me a lot in preparing this complaint.

I find it very hard to write this. It took me 3 years to write about it (lots of work with psychologists and help lines preparing for this and writing it down). I am trying to describe everything as accurately as I can. Unfortunately many of these memories cause high levels of stress. It quickly triggers PTSD response and shuts down my ability to think. Often I have to take a long break or can continue only the next day. I do not know if I need to describe every event, so I tried to be brief in complaint. If there is more information required please let me know. It is very important for my wellbeing on many levels that I provide all the required information. Even if it is difficult I have no choice but to write it. Besides preventing paying legal fees to Pryde for scamming and manipulating me and possibly getting some compensation it is also very important for me to get some feeling of justice. I was severely affected by trauma and Pryde promised to help, but instead he abused his position of power. Dealing with Pryde was a traumatic experience and instead of dealing with single event trauma I have to deal with complex trauma now. Of course there are other factors like QBE doing what is required by law from insurance companies or Potts not running a scam and so on. I never thought such things could happen in Australia. I thought I left these things behind when we left the Soviet Union. I can imagine it somewhere in Russia, but this is Australia. It is meant to be civilized and lawful.

By some I was recommended to forget and move on. However, that is avoidance and is the worst thing you can do when having PTSD.

The only path is retelling the story and processing the emotions first with the help of a counselor, so that I can talk about these things, then seeking justice and telling it to everyone it matters. I will publish my story, so that everyone who gets injured in a similar way can avoid getting the same horrible experience. Find every journalist that would be interested to retell my story, that other people, even not affected by these problems, are aware of them and can help others who might be affected.

Attachments

2023-07-17 Reasons for late submission of complaint.pdf

2023-06-07 Lawpartners scam.pdf

2023-06-07 Analysis of Lawpartners Itemised Bill.pdf

2020-05-06 Letter (Advice) - from counsel confirming discussions with client re Ms Moodley's report and failed settlement attempt.pdf

2023-07-17 Juste Stoniene. Statement re Kent Pryde.pdf

Alfonsas Stonis 2023-07-17