JDR2 Claimants Bundle of Additional Evidence

Filed on behalf of the Claimant

Witness Statement of Julian Diaz-Rainey

Statement No. 2

Date: 1 July 2024

Exhibits: JDR2

CASE NO: BL-2023-000713

IN THE HIGH COURT OF JUSTICE

THE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES

CHANCERY DIVISION

BETWEEN:

JOCKEY CLUB RACECOURSES LIMITED

Claimant/Applicant

-and-

(1) DANIEL FRANK PETER KIDBY

(2) PERSONS UNKNOWN ENTERING THE AREA DESCRIBED BELOW AS THE

“RACE TRACK” ON THE DAY OF A “RACING FIXTURE”, EXCEPT AT

“CROSSING POINTS” WITH “AUTHORISATION”, AS DESCRIBED BELOW

(3) PERSONS UNKNOWN ENTERING AND/OR REMAINING ON ANY “CROSSING

POINTS” WITHOUT “AUTHORISATION” ON THE DAY OF A “RACING FIXTURE”,

AS DESCRIBED BELOW

(4) PERSONS UNKNOWN ENTERING THE AREA DESCRIBED BELOW AS THE

“PARADE RING” WITHOUT “AUTHORISATION” ON THE DAY OF A “RACING

FIXTURE”, AS DESCRIBED BELOW

(5) PERSONS UNKNOWN ENTERING AND/OR REMAINING ON ANY PART OF THE

AREAS DESCRIBED BELOW AS THE “HORSES’ ROUTE TO THE PARADE RING”

AND/OR THE “HORSES’ ROUTE TO THE RACE TRACK” WITHOUT

“AUTHORISATION”

ON THE DAY OF A “RACING FIXTURE”, AS DESCRIBED BELOW

(6) PERSONS UNKNOWN INTENTIONALLY OBSTRUCTING THE “HORSE

RACES”, AS DESCRIBED BELOW

(7) PERSONS UNKNOWN INTENTIONALLY CAUSING ANY OBJECT TO ENTER

ONTO AND/OR REMAIN ON THE “RACE TRACK” WITHOUT “AUTHORISATION”

ON THE DAY OF A “RACING FIXTURE”, AS DESCRIBED BELOW

(8) PERSONS UNKNOWN INTENTIONALLY ENDANGERING ANY PERSON AT THE

LOCATION DESCRIBED BELOW AS THE “EPSOM RACECOURSE” ON THE DAY

OF A “RACING FIXTURE”, AS DESCRIBED BELOW

(9) MR BEN NEWMAN

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