Witness Statement of Charlie Boss and Exhibit CB1

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Beth Kelly Associate

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From: Beth Kelly Sent: Monday, July 1, 2024 5:39 PM To: d.f.p.kidby@outlook.com; ben.john.newman@gmail.com Cc: Andrew Mitchell <Andrew.Mitchell@pinsentmasons.com>; Julian Diaz-Rainey <Julian.Diaz- Rainey@pinsentmasons.com> Subject: BL-2023-000713. Jockey Club Racecourses Limited v Kidby & Others

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File(s): BL-2023-000713 - Draft Order - 01.07.2024.docx BL-2023-000713 - N244 Application to rely on additional witness evidence - signed - 01.07.2024.pdf Second Witness Statement of Julian Diaz-Rainey - signed - 01.07.2024(149286999.1).pdf JDR2 - FINAL.pdf Animal Rising - look back on 2023.mov Dear Mr Kidby, Mr Newman, We refer to the above matter. Due to a change of circumstances which affects our client’s evidence, our client has today filed an application with the Court seeking permission to rely on additional evidence. By way of service, please find attached: 1. Form N244 – Application for permission to rely on additional evidence; 2. Draft Order; 3. Second Witness Statement of Julian Diaz-Rainey; and 4. Exhibit JDR2 (please note that this includes the attached video recording at page 474). We have asked the Court to determine the application at the Disposal Hearing which is to be listed for a 1 day hearing in a 2-day window covering 8 July 2024 and 10 July 2024.Alternatively, if the Court is minded to determine the Application separately, the Applicant considers that it is suitable to be determined by a Master on the papers. Please note, that there is no requirement for you to attend the Disposal Hearing, as the claim against you has been stayed further to the sealed Tomlin Order dated 20 April 2024.

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