Witness Statement of Charlie Boss and Exhibit CB1

Docusign Envelope ID: ABA671A3-E271-4EC4-AB06-1088FEC37456

of the extensive crowdfunding campaign AR is presently running to raise money for the

criminal trial later this year.

Byelaws

52. I can confirm that there have been no changes to the Byelaws made by the Epsom &

Walton Downs Conservators in 2013, pursuant to s. 11 of the Epsom and Walton Downs

Regulation Act 1984, which were in place at the time the Interim Injunction and Final

Injunction were ordered.

The Annual Review

53. The Claimant made this application pursuant to paragraph 5 of the Final Injunction Order,

entitled “ Annual Review ”, by which Sir Anthony Mann ordered that “ The Claimant shall issue

an application notice, returnable in the Applications Court on a date within 14 days either

side of the anniversary of this Order, and shall give notice of the application by the

Alternative Service Methods .”

54. The Claimant applies to amend the Annual Review process as ordered by Sir Anthony

Mann, to include orders that:

54.1

the Claimant shall, if it seeks the continuation of the Injunction, issue an application

notice, returnable in the Applications Court on a date within 14 days either side of the

anniversary of the order following the first annual review (the “ Annual Review

Order ”); and that

54.2

if no application is made in accordance with the above, the Injunction will expire on the

anniversary of the Annual Review Order and the proceedings will be at an end.

55. In doing so, the Claimant seeks a direction that if, in one year’s time, the Claimant no longer

seeks to enforce the Injunction, it does not need to make a further application to the Court

for a further annual review. This is due to the costs involved in bringing further applications.

In particular, the Claimant is required constantly to balance the costs and risks involved in

running its business and carrying on the sport of horse racing, and remains of the view that

the ongoing risk of disruption (as set out above) clearly justifies the costs involved in

maintaining the Injunction by way of the annual review process. However, should that

balance materially change over the course of the following year such that the Claimant no

longer seeks to enforce the injunction, the Claimant would seek to avoid incurring further

costs, and using further of the Court ’s time in making a further application.

Cross-undertaking