Docusign Envelope ID: ABA671A3-E271-4EC4-AB06-1088FEC37456
2. This is my first witness statement in these proceedings. I am duly authorised by the
Claimant to make this statement on its behalf in support of its application for an order that
the injunction, in the terms of the Order of Sir Anthony Mann dated 9 July 2024 and sealed
on 10 July 2024 (the “ Injunction ” and “ Final Injunction Order ” , respectively), be continued
for the remainder of the five-year period set out in the Final Injunction Order, subject to further annual review (the “ Application ”). 1
3. Unless stated otherwise, the facts and matters set out in this witness statement are within
my knowledge and are true. Where any facts or matters are not within my own knowledge,
the source of the information is identified and those facts and matters are true to the best of
my knowledge and belief.
4. There is now produced and shown to me marked exhibit "CB1", a bundle of true copy
documents to which I refer in the course of this witness statement. Save where stated
otherwise, references below to page numbers are to the pages of exhibit "CB1". There is
now also produced and shown to me the two bundles of evidence filed ahead of the
disposal hearing on 8 July 2024 (the “ Evidence Bundle ") and the (the “ Additional
Evidence Bundle ").
Background
5. The background to this matter has been set out extensively in:
5.1
the first and second witness statements of Nevin Truesdale, Chief Executive Officer of the Claimant between August 2020 and December 2024 2 (“ Truesdale 1 ” and “ Truesdale 2 ”), and the Affidavit of Nevin Truesdale (given in Committal Proceedings against the Ninth Defendant, summarised below); 3
5.2
the first witness statement of Amy Starkey, Managing Director of Racecourses of the
Claimant between May 2024 and May 2025, previously Managing Director of East, London and Small Courses from January 2023 to June 2024 4 (“ Starkey 1 ”) ;
5.3
the first witness statement of Dickon White, Aintree and North-West Regional Director for the Claimant 5 (“ White 1 ”) ;
5.4
the first witness statement of Simon Knapp, Senior Veterinary Surgeon for London Region Races at the Claimant 6 (“ Knapp 1 ”) ; and
1 Pages 2-9 of CB1 2 Pages 249-263 / 531-539 of the Evidence Bundle 3 Pages 4-19 of the Evidence Bundle
4 Pages 382-406 of the Evidence Bundle 5 Pages 407-440 of the Evidence Bundle 6 Pages 441-445 of the Evidence Bundle
2
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