A pre-removal risk assessment is argued on paper. You can file written submissions and hire a lawyer or other counsel to help, at your own cost. If you are relying on evidence that was not before the Refugee Protection Division, you have to point to it specifically and explain how it applies to you, because the decision-maker is not obliged to hunt through your package for it.
(1)Subject to section 166, a person applying for protection may make written submissions in support of their application and for that purpose may be assisted, at their own expense, by a barrister or solicitor or other counsel.
(2)A person who makes written submissions must identify the evidence presented that meets the requirements of paragraph 113(a) of the Act and indicate how that evidence relates to them.