Docusign Envelope ID: ABA671A3-E271-4EC4-AB06-1088FEC37456
remainder of the 2024 racing season until October 2024. It was posted at such intervals
again on 5 June 2025, ahead of the 2025 Derby Festival, which took place on 6 – 7 June
2025. Mr Allen has confirmed to me that, following the Derby, the copies of the Order
remain in place as posted, and the Order will remain displayed for the rest of the 2025
racing season, until 28 September 2025.
59. I am now aware that, regrettably, the Order was posted around the Race Track two days,
rather than three days ahead of the main racing fixture, the Epsom Derby, and one day
before the Oaks, i.e. the first day of the Derby Festival. I have also been informed by Mr
Allen that at the first racing fixture of the year, on 22 April 2025, the Order was not posted at
50-metre intervals around the Race Track. The Claimant has undergone several operational
changes over the past year, and unfortunately, due to a management oversight, the Order
was not posted three days ahead of each fixture.
60. From 1 September 2025 I will commence a new role as CEO of Jockey Club Racecourses
with overall responsibility for the Claimant’s activities, including the proper upkeep of the
Order. I understand the importance of proper service and will make it a priority of mine to
ensure that such oversights do not happen again. To ensure that there are no further delays
or oversights in the posting of the Order, if the Injunction is continued, I will (i) arrange a
briefing with the operational team at Epsom including Mr Simon Durrant General Manager of
Kempton Racecourses (and Silver Command’ for the 2025 Epsom Derby Festival leading
the Safety and Security Plan for the event) and Mr Allen, to discuss and align on the
operation of the Injunction, and the steps which they need to take and to be aware of, and
when, (ii) oversee that calendar alerts are set 10 days in advance of each of the remaining 8
racing fixtures of this season, to ensure that the necessary arrangements are made for the
timely posting of the Order ; and (iii) ensure the Claimant’s compliance with any further Order
the Court may make.
61. A copy of the Final Injunction Order was also served on Mr Newman by email, exhibited at page 216 of CB1 58 .
62. In accordance with paragraph 6 of the Final Injunction Order, I confirm that the Application
Notice, this witness statement and the draft Order will be served on the Second to Eighth
Defendants by way of the Alternative Service Methods.
Statement of Truth
I believe that the facts stated in this witness statement are true. I understand that proceedings
for contempt of court may be brought against anyone who makes, or causes to be made, a false
statement in a document verified by a statement of truth without an honest belief in its truth.
58 Page 216 of CB1
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