Yet another RTR issue

I’m not sure if I’m losing the plot here or Wick are.

The client (have posted about this case previously) is an 8A national who had unrestricted permission to work as of 30/4/04. She had also working on 30/4/04 and had done so without interruption for 12 months. She therefore meets both Reg 2 (2) and (3) of the Accession (I&W) regs.

Firstly- whilst we’ve provided Wick with confirmation of her unrestricted PTW, they are still insisting on us providing evidence of the start/end dates of the job she had as of 30/4/04. As far as I can see, as we’ve already provided confirmation that she meets Reg 2 (2) there should be no requirment to demonstrate she meets Reg 2 (3) as well- or am I missing something?

Secondly- Wick is quoting Reg 6 (2) of the immigration (EEA) regs and basically requesting evidence that client can be treated as a worker (ie- work seeking or temporarily incapacitated) for every period from 2004 onwards up to the date of her ESA claim. Client has variously worked for some periods, been incapacitated for some others, occasionally been registered as unemployed and at other times been ‘self sufficient’ (supported by her UK citizen husband who was working during some of the period). I can’t for the life of me decide whether this is correct or not- if she was legally living & working in the UK prior to April 2004 surely she no longer has to demonstrate that she has a RTR or am I missing the point?

As per usual, any & all suggestions welcome…

Thanks. Yes- it was limited leave (2 years). TBH, I think I’ve been so obsessed with getting around the registered worker problem that the other issue sort of escaped me. Will have to see whether we can argue that she had a permanent right of residence as of the date of her ESA claim. I’m not sure where things stand regarding periods prior to 2004 when considering the 5 year requirements?