Witness Statement of Charlie Boss and Exhibit CB1

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

56. As in previous years, the Claimant remains willing to give a cross-undertaking in damages in

respect of any losses which may be suffered by the Respondents should the Court

subsequently find that the proposed Order should not have been made. Exhibited at pages

170 to 209 of CB1 is a copy of the Claimant’s most recent accounts filed at Companies House. 52

Service

57. I confirm that the Claimant has complied with the steps set out at paragraph 7(i) of the Final

Injunction Order for the service of the Final Injunction Order on the Second to Eighth

Defendants, by: (i) posting digital copies on its website and Facebook page; (ii) affixing

sealed copies in transparent containers at public entrances to the Epsom Racecourse; and

(iii) providing digital copies by email to Mr Kidby (in his capacity as co-founder of AR) (“ the

Alternative Service Methods ”) . Specifically:

57.1

On 11 July 2024, the Claimant posted the Final Injunction Order on its website. I enclose at pages 210 to 211 of CB1 53 screenshots of the Claimant’s website.

57.2

On 11 July 2024 at around 1:20pm, the Claimant posted a link to the relevant news

page of the Claimant’s website containing the Final Injunction Order on its Facebook page. I enclose at page 212 of CB1 54 a screenshot of the Facebook post.

57.3

Although not directed by the Court, the Claimant also posted confirmation of the Final

Injunction Order on its X account on 11 July 2024 at 12:40pm. I enclose at page 213 of CB1 55 a screenshot of the X post.

57.4

On 12 July 2024, the Claimant affixed sealed copies of the Final Injunction Order in

transparent containers at public entrances to the Epsom Racecourse. I enclose

images of the Final Injunction Order posted at Epsom Racecourse at pages 214 to 215 of CB1 56 .

57.5

On 11 July 2024 at 11:30, the Claimant served a digital copy of the Final Injunction Order by email on Mr Kidby. I enclose this email at page 216 of CB1 57 .

58. By paragraph 7(ii) of the Final Injunction Order, Sir Anthony Mann also ordered that that

Order be served on the Second to Eighth Defendants, not less than three days before each

Racing Fixture, by posting the Order at 50-metre intervals along that part of the perimeter of

the Race Track. I am informed by Mr Allen that the Order was posted at 50-metre intervals

along the perimeter of the Race Track on 15 July 2024 and remained in place for the

52 Pages 170 - 209 of CB1 53 Pages 210 -211 of CB1 54 Page 212 of CB1 55 Page 213 of CB1 56 Pages 214 - 215 of CB1 57 Page 216 of CB1

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