Witness Statement of Charlie Boss and Exhibit CB1

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

paragraphs 49 to 51). By knowingly breaching the Order, Mr Newman joined himself

as Ninth Defendant to these proceedings.

8.3

The Claimant brought a successful contempt of court application against Mr Newman

(the “ Committal Proceedings ”) . By the order of Mr Justice Miles dated 13 October

2023, Mr Newman was given a further suspended custodial sentence (the “ Committal Order ”). 12 During the Committal Proceedings (as recorded in the Committal Order), Mr

Newman admitted to having breached the Interim Injunction Order, and gave

undertakings to comply with the terms of the injunction until 11 April 2025, or until he

was no longer bound by an injunction in these proceedings.

8.4

In April 2024, Mr Kidby and Mr Newman, the First and Ninth Defendants, each gave

undertakings to the Court that they would not carry out the acts set out in the Interim

Injunction Order for a period of five years, in exchange for the Claimant agreeing not

to pursue costs against them. On the basis of the foregoing, it was ordered by consent

on 22 April 2024, that the Claim be stayed as against the First and Ninth Defendants.

8.5

On 10 July 2024, Sir Anthony Mann, sitting as a High Court Judge, granted the

Claimant’s application for a Final Injunction Order in the terms of the Interim Injunction

Order. Pursuant to paragraph 4 of the Final Injunction Order, the injunction was to

remain in force for five years, subject to annual review.

9. The present Application is brought pursuant to paragraph 5 of the Final Injunction Order. I

understand that the Claimant is subject to a duty of full and frank disclosure in making the

present Application, and in this witness statement, I seek to update the Court on all relevant

facts and matters accordingly.

The Epsom Racecourse

10. Paragraphs 20 to 27 of Truesdale 1 set out the particular geography of the Epsom

Racecourse, relevant both to the need for, and operation of, the Injunction. Aerial photographs of Epsom Racecourse are included in Truesdale 1. 13 There have been no

material changes to the layout, or use of, the Racecourse and Race Track (as defined at

paragraph 3(6) of the Final Injunction Order) since Mr Truesdale’s evidence was given, and

since the Final Injunction Order was granted in July 2024.

11. I note, in particular, that the Racecourse is particularly vulnerable to trespass. This is

because, unlike other racecourses, it is possible for the public, with no requirement for a

ticket, to enter a large area in the centre of the Racecourse referred to as “the Hill”, as well

as to other areas, to watch the Derby and other racing fixtures.

12 Pages 1060 - 1064 of the Evidence Bundle 13 Pages 276 – 281 of the Evidence Bundle

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