1 Table of contents 250

Witness Statement of Charlie Boss and Exhibit CB1

1. Sealed Order of Sir Anthony Mann - 10 July 2024		24
2. Welcome to Horse Pwr Website		50
3. YouTube - Alex Lockwood, “We Made FRONT-PAGE News 12 Times in 2023 For Protecting Animals” – posted on 21 December 2023		91
4. Animal Rising website, 'Campaigns’		92
5. Animal Rising website, ‘Taking animal rights to trial’		93
6. Animal Rising website, 'Support the Grand National Protesters in their Crown Court Trial'		105
7. Animal Rising website, ‘Our History’		111
8. Animal Rising website, Press, _Grand National Protestors Sentenced Following 2023 Aintree Delays_ - 2 May 2025		115
9. Animal Rising website, Press, _Pleas Of Animal Rising Supporters Blocked At Staines Magistrates Court_ – 4 April 2025		117
10. Animal Rising website, Press, _ Grand National Protestor Case Dropped_ – 17 December 2024		119
11. Animal Rising website, Press, “Grand National Protestors Plead Not Guilty to Public Nuisance” – 6 November 2024		121
12. Animal Rising website, Press, “All Charges Dropped Against Epsom Derby 2022 Disruptors” – 23 September 2024		123
13. Followers of @AnimalRising on Instagram		125
14. Followers of @AnimalRising on X		126
15. YouTube – “Willy De Houelle dies at 2025 Grand National _ Claudia Penna Rojas on BCB Radio _ 4 April 2025” – posted on 7 April 2025		127
16. Animal Rising website, ‘Donate to support the movement for animals and nature’		128
17. @AnimalRising post on X – 13 May 2025		130
18. @AnimalRising post on X – 3 May 2025		131
19. @AnimalRising post on X – 18 April 2025		132
20. @AnimalRising post on X – 12 April 2025		133
21. @AnimalRising post on Instagram – 9 November 2024		134
22. Marshall BioResources Acres website		135
23. @AnimalRising - Video post on X - 17 April 2025		140
24. Animal Rising website, Press, _Animal Rising Found Guilty in Dairy Blockade Trial’_ – 1 April 2025		141
25. Animal Rising website, Press, “Two Animal Rising Supporters Sentenced After Müller Dairy Protest” – 19 February 2025		143
26. RMG - Record Number of Broadcasters to Showcase Derby		145
27. Just Stop Oil website, Press, “We are hanging up the hi-vis” – 27 March 2025		148
28. Sky News, “Direct action group Just Stop Oil holds final protest, claiming it has been 'successful” – 26 April 2025		153
29. Just Stop Oil website, “Just Getting Started”		163
30. Action Network website, _Join the Umbrella Revolution_		170
31. The Standard, “Who are the protestors behind Youth Demand, the pro-Palestine climate activism group_” – 31 March 2025		174
32. Independent, _London Marathon disrupted as red powder paint thrown by pro-Palestine protesters_ - 28 April 2025		184
33. Youth Demand website, “Young People Are Resisting, Help Us Grow The Resistance”		194
34. Epsom & Ewell Borough Council Public Spaces Protection Order No.1 of 2025		199
35. Jockey Club Racecourse Limited, Report and Financial Statements, 31 December 2023		201
36. JCR Website News page- Evidence of Service- Final Order		241
37. JCR Facebook- Evidence of Service- Final Order(149567240.1)		243
38. JCR X- Evidence of Service-Final Order(149567258.1)		244
39. Service of Order - Posting at racecourse		245
40. Service of Order - Email to Kidby and Newman enclosing final Order - 11 July 2024		247
Insert from: "BL-2023-000713 - 2025 06 24 - Witness Statement of Charlie Boss and exhibit CB1 (signed).pdf"		1
1. I am the Interim Group Chief Executive of the Claimant and have held this position since 9 December 2025. I was previously Chief Commercial Officer of the Claimant between March 2021 and April 2023. In April 2023, I left the Claimant for a role at ...		1
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...		2
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 matte...		2
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". T...		2
Background		2
5. The background to this matter has been set out extensively in:		2
5.1 the first and second witness statements of Nevin Truesdale, Chief Executive Officer of the Claimant between August 2020 and December 2024 (“Truesdale 1” and “Truesdale 2”), and the Affidavit of Nevin Truesdale (given in Committal Proceedings agai...		2
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 (“Starkey 1”);		2
5.3 the first witness statement of Dickon White, Aintree and North-West Regional Director for the Claimant (“White 1”);		2
5.4 the first witness statement of Simon Knapp, Senior Veterinary Surgeon for London Region Races at the Claimant (“Knapp 1”); and		2
5.5 the first and second witness statements of Julian Diaz-Rainey, partner of the firm, Pinsent Masons LLP, solicitors for the Claimant (“Diaz-Rainey 1” and “Diaz-Rainey 2”).		3
6. In summary, the Claimant is the largest commercial horseracing organisation in the UK, and the freehold owner of the Epsom Racecourse (the “Racecourse”) (further background information in respect of the Claimant is set out at paragraphs 7 to 9, and...		3
7. The Claimant hosts the two-day Epsom Derby Festival, with the prestigious Epsom Derby race held on the first Saturday of June each year. Further background to the Derby Festival is set out in paragraphs 13 to 17 of Truesdale 1.		3
8. A summary of the proceedings to date is set out below, as context for the evidence given in my witness statement. I was not personally involved in these proceedings up until the present Application; however, I have read the witness statements and a...		3
8.1 Animal rights protesters affiliated with the group Animal Rising (“AR”), caused significant disruption to the 2022 Derby, the 2023 Grand National, and further races in Ayre and Doncaster in 2023 (as set out in Truesdale 1, paragraphs 35 to 48, and...		3
8.2 The Interim Injunction Order was knowingly breached by Mr Newman who ran onto the racetrack during the running of the Epsom Derby on 3 June 2023, exposing himself, the horses and jockeys, police officers and stewards, and wider racegoers to seriou...		3
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 Ord...		4
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 agre...		4
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 w...		4
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 u...		4
The Epsom Racecourse		4
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. There have been no m...		4
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 re...		4
12. Moreover, the angles of the Race Track mean that acts of trespass during a race are particularly dangerous for all those present – human and equine. This is because there are several ‘blind corners’, which mean that a protester may be unable to se...		5
13. I also confirm that, as set out at paragraphs 28 to 34 of Truesdale 1, equine safety remains fundamental to everything the Claimant does and to the sport of horse racing. The Claimant continues to invest in its facilities to ensure it offers equin...		5
The continued compelling need for an injunction		5
14. As noted above, animal rights protesters affiliated with AR caused significant disruption to numerous racing events in 2022 and 2023. Such disruption continued even with the interim injunction in place, which Mr Newman knowingly breached (as he ad...		5
15. Disruptive protests were not staged at the Grand National held this year on 5 April 2025, or the Epsom Derby on 7 June 2025. In that respect, the situation remains the same as it was in July 2024, when the five-year injunction was granted over the...		5
16. As addressed in paragraphs 6 to 9 of Diaz-Rainey 2, AR updated its website shortly before the Final Injunction hearing on 8 July 2024, removing references to its plans to disrupt horse-racing activities (as referenced in paragraph 22 of Truesdale ...		5
17. AR has since made further changes to its website. However, I believe these only demonstrate its continued focus on ending horse racing (along with other campaigns), and ongoing celebration of the disruption of sporting events. In particular:		6
17.1 The “CAMPAIGNS” section of AR’s website contains reference to four campaigns, further to a separate page entitled “Our history” and a separate page entitled “Campaigns we support”. One of the four campaigns is entitled “Taking animal rights to t...		6
“Horse racing is an outdated practice that is ready to be resigned to history.		6
In 2022 we disrupted the Epsom Derby, then followed it up with the Summer of Animal Rising. Our planned disruption of the 2023 Grand National made headlines, sparking a national conversation about the cruelty of horse racing. The race was delayed, and...		6
It didn't end there - we disrupted the Scottish Grand National, followed by delaying the races at Doncaster, and then taking fight for horses to the Epsom Derby, again, in June. Whilst brave supporters delayed the race inside, a celebration took place...		6
17.2 The page includes a slideshow of several pictures of protesters at horse racing events, climbing or preparing to climb over fences, being arrested or apprehended by police, and in particular, of Mr Newman being chased by security personnel on the...		6
17.3 Under the text set out above, the website includes a click-through link with the text “Support”, which leads to a page allowing visitors to make donations to “SUPPORT PEOPLE STANDING UP FOR HORSES IN COURT”. This page includes the following text:		6
“In 2023, we delayed the start of the Grand National and created a national conversation about the cruelty of horse racing. Now, 45 people have been charged with public nuisance. This is a huge opportunity to put horse racing on trial before a jury. T...		7
17.4 This page allows supporters to make one-off or monthly payments, and records that numerous and frequent payments were made since the page was published on 8 November 2024 until at least 22 June 2025.		7
17.5 Also under the page entitled “Taking animal rights to trial”, AR trumpets “the disruption of the English Greyhound Derby” in 2023, and the group’s actions to “free” beagle dogs from a breeding facility in December 2022.		7
17.6 Under the page entitled, “Our History”, AR further celebrates what it calls the “2023 Summer of Animal Rising”, with the following text:		7
“In the Spring of 2023 we launched Animal Rising with our boldest action yet: more than 100 people aiming to halt the Grand National, the UK's largest horse racing event.		7
Our intervention achieved 9 front-pages and hours of broadcast air-time, all shining a spotlight on our broken relationship with animals and nature.		7
But we weren't done there, as we disrupted three more horse racing events, occupied an intensive dairy farm, rescued three sheep from the King's land, demonstrated outside half of the UK's remaining greyhound racetracks and dropped a banner at the Gre...		7
18. AR has also posted a number of press releases on its website since the five-year Injunction was ordered in July 2024, calling for an end to horse racing, and for protest action to achieve this aim. These are summarised below, beginning with the mo...		7
18.1 A press release posted on AR’s website on 2 May 2025 refers to deaths of horses over the course of certain racing events, and includes the following statement by AR campaigner, Claudia Penna Rojas:		7
“2025 has been a terrible year for horse racing. The shocking deaths at this year’s Grand National and Scottish Grand National laid bare the brutal reality of the sport to the viewing public. Week after week, horses are pushed to their limits and lose...		8
18.2 A press release on AR’s website dated 4 April 2025 refers to the ongoing criminal proceedings against ten individuals who were arrested at the Epsom Racecourse on 3 June 2023. The press release describes these individuals as having been arrested...		8
“This weekend brings yet another episode of televised cruelty in the form of the Grand National, even though the British public are moving away from cruel and harmful industries like horse racing. As the truth about the breaking-in, whipping, injuries...		8
How many horses have to die, like Willy De Houelle just yesterday, before we truly embrace what it means to be a nation of animal lovers? We must work together to create a world where the animals currently trapped in horse racing, greyhound racing, an...		8
18.3 A press release posted on AR’s website on 17 December 2024 notes that charges of public nuisance and criminal damage against an individual who was due to stand trial in September 2025 for her actions seeking to disrupt the Grand National in 2023...		8
“I have watched horses die at the Grand National since I was a child seeing the race on TV. It’s barbaric that we still allow this to happen year after year, not to mention the thousands of horses dying over the years at other races around the country...		8
18.4 Similarly, a press release posted on AR’s website dated 6 November 2024, refers to the arrests of 118 people at the Grand National in 2023 for their actions which delayed the race for 15 minutes. It is noted that 9 of 18 of those charged pleaded...		9
“While horses continue to suffer in British racing, we will be calling for an end to this abhorrent “sport.” The protests at the Grand National hit a nerve and continue to impact the industry to this day. The sheer level of support that we’ve had show...		9
18.5 A press release on AR’s website dated 23 September 2024, referenced the charges having been dropped for “six Animal Rising Supporters that disrupted the Epsom Derby in 2022” as a success for the group. The press release referred to Mr Newman “su...		9
“The Jockey Club is aware of the cruel and unnecessary realities of horse racing, and is doing everything it can to protect a dying industry. We proudly stand by our actions; these charges being dropped is another step towards the end of racing in Bri...		9
19. AR has also continued to use its social media channels to call for an end to horseracing, including by celebrating the actions of protesters, as summarised below. I note that the group’s following on social media has only increased since Truesdale...		9
20. On 7 April 2025, AR posted an interview with Ms Rojas on BCB Radio, seemingly from 4 April 2025, on its YouTube page:		9
20.1 Ms Rojas referred to horseracing as “televised cruelty for the sake of profit”, and called for the need to “stop racing [horses] to the death.” When asked to comment on AR’s support for “peaceful protest”, Ms Rojas referred in particular to the p...		10
20.2 In light of these comments, I understand the statements on AR’s website (noted at paragraph 18.1 above) that people feel compelled to engage in “peaceful protest”, to include disruptive protest and trespass, such as those carried out at the Grand...		10
20.3 Ms Rojas also stated in the radio interview that: “People are turning their backs on the industry. We’ve seen in Cheltenham this year, they had the lowest recorded crowd since 1993, so time is ticking on this industry, and the faster we can make ...		10
20.4 The video was captioned by AR as follows: “Supporters of Animal Rising attempted to stop the horses from being forced to race in the 2023 Grand National, causing a 15 minute delay. Public Nuisance trials are scheduled for later this year after ov...		10
21. AR has also posted frequently on its X (formerly Twitter) feed during the course of this year, calling for an end to horseracing, and celebrating the actions of those who disrupted the races in recent years:		10
21.1 A post, dated 13 May 2025, states:		10
“While we fully support road safety awareness around horses, the biggest killer of horses in Britain isn’t traffic, it’s racing.		10
214 horses died on UK racecourses in 2024 - nearly 4x more than on roads.		10
And it’s broadcast on mainstream TV throughout the year. #BanHorseRacing #GrandNational.”		10
21.2 A thread, dated 3 May 2025, states as follows, and includes a link to AR’s website, seeking donations:		10
“9 Animal Rising supporters were sentenced for their participation in 2023's disruption of the Grand National, calling for a ban on the cruel "sport". They were each handed 200+ hours of community service, alongside £133 in court fees. #grandnational ...		11
Even though the public recognise that the Grand National’s time is up, and horses continue to die year after year in the name of “sport”, the Crown Prosecution Service still see it fit to pursue convictions and punishment for those who try to protect ...		11
✊ Donate to the trial support fund, and help defendants facing legal action for taking a stand against cruelty.”		11
21.3 A post, dated 18 April 2025, states as follows:		11
“The latest racing horse deaths, most recently at Cheltenham, reveal “exercise-associated sudden death” is the racing industry’s new buzzword.		11
Whether these horses die of heart attacks, broken necks, or “undetected” respiratory failure is irrelevant. A horse will die every other day on a British track, and the racing industry is entirely to blame.”		11
21.4 A post, dated 12 April 2025, states as follows:		11
“Today we saw the few horses who made it to the finish line at the Scottish Grand National violently whipped, while multiple horses fell or pulled up injured.		11
We cannot call ourselves a nation of animal lovers while turning a blind eye to the violence of horse racing.		11
Over the last week, this industry has exposed its grim reality to the viewing public. This cruelty won’t end until racing is halted for good.”		11
22. A post on AR’s Instagram, dated 9 November 2024, referred to the “Grand National: Horse Protectors in Court”, stating that 24 “brave campaigners” appeared in court and pleaded not guilty to public nuisance. It referred to the delay of the Grand N...		11
23. Further to the abovementioned statements in respect of horseracing, AR continues to champion other disruptive action. Indeed, it appears to me that disruption remains at the core of AR’s ideology as a method to achieve media attention and further ...		12
23.1 Under the “CAMPAIGNS” section of AR’s website, AR includes a page entitled “FREE THE MBR BEAGLES.” Here, AR celebrates its actions in 2022 by taking 18 beagle dogs from Marshall BioResources Acres, a facility where I understand dogs are bred for...		12
23.2 A video post on AR’s X feed on 17 April 2025 showed AR supporters (including Mr Kidby and Mr Newman) on their way to Court in connection with charges brought against them for their taking animals from the facility in 2022. One individual states ...		12
23.3 A press release posted on AR’s website on 1 April 2025, stated that four AR campaigners were found guilty in a trial of public nuisance, celebrating the “succession of nationwide actions taken by Animal Rising in September and October 2022, whic...		12
“Those who took part in our peaceful campaign against dairy giants didn’t do so lightly. They felt compelled to take action because of the environmental destruction and animal suffering caused by this outdated, harmful system.”		12
23.4 Similarly, a press release on 19 February 2025, in relation to the sentencing of AR supporters involved in the abovementioned blockades at the Müller’s site in Droitwich, celebrated the protesters having caused “milk shortages across the nation”...		13
24. Considering the frequency and vehemency of the statements on AR’s website and social media channels calling for an end to horseracing, and the repeated celebration and drumming up of support for individuals who previously disrupted the races, I co...		13
25. I note that the Claimant has not received any further communications from AR regarding its intention to disrupt the races as were received in 2023 (as set out in Starkey 1, paragraphs 7 to 9). However, this was also the case in 2024, when the Fina...		13
26. In particular, it is my understanding that AR continues to operate as a collection of persons who share a common purpose, rather than a corporate entity with a particular hierarchical structure (as noted in Truesdale 1, paragraph 10; Truesdale 2, ...		13
27. For completeness, I note that, as referenced at paragraph 19 of Truesdale 2, a spokesperson for AR, Mr Nathan McGovern, made a statement to the press on 4 April 2024, stating that AR would not target the Grand National in 2024 because the public h...		13
28. Surrey Police have informed us that there were four arrests made on the day of the 2025 Derby but these that these were related to ‘drunk and disorderly’ offences, rather than in relation to protest action.		14
Wider protest action		14
29. Further to the abovementioned actions of AR, Mr Truesdale set out in 2024 that there was “a clear recent history of activist organisations targeting high profile sporting events to seek to attract media attention and further their agenda through d...		14
30. Environmental activist group, Just Stop Oil (“JSO”), disrupted a number of sporting events in 2023, as detailed at paragraph 26 of Truesdale 2. On 27 March 2025, JSO issued a press release stating that it was “hanging up the hi vis”, indicating it...		14
31. Furthermore, Youth Demand (“YD”), a political and environmental youth activist organisation affiliated with JSO, was established in 2024. On 27 April 2025, YD affiliates jumped over the barriers during the London Marathon on Tower Bridge, and in...		14
32. The Claimant has not received any direct indication from JSO or YD that they intend to disrupt horseracing. However, in light of JSO’s public statement regarding a new direct action campaign, coming soon, and YD’s recent establishment, targeting s...		15
The Impact of Trespass and Disruption		15
33. As summarised below, including by reference to earlier evidence given in these proceedings, the disruptive actions of protesters at the Epsom Racecourse have significant and wide-ranging deleterious effects on the following groups.		15
The Horses and the Jockeys		15
34. I refer the Court to the first witness statement of Simon Knapp, the Claimant’s Senior Veterinary Officer for London Region Races, for a detailed assessment of the impact of disruptive action on the horses and jockeys. As detailed in paragraph 15,...		15
35. In particular, he notes that the young colts raced in the Derby are “akin to hormonal adolescents”, and in addition to weighing around 500kg, are “excitable”, “unpredictable” and “difficult to control”, particularly if there is any delay or disrup...		15
36. I am informed by Jim Allen, Epsom General Manager for the Claimant, that he has spoken with Mr Knapp, who remains in his role and has confirmed that the information contained within his statement remains correct and there are no material updates.		15
The Protestors, police and security staff, and the public		15
37. Protesters at race meetings put themselves, police and security personnel, and the public, at significant risk. As set out in the affidavit of Mr Truesdale at paragraph 57.2, it took the actions of at least three police officers and three stewards...		15
38. Should further people (for example, members of the public) enter the Race Track, either to assist the stewards and the police, or to further the protest, then the danger to life would only increase. Moreover, delayed and cancelled races, and possi...		16
Additional Event Costs and Organisation		16
39. As a result of the threats of trespass and disruption, and the acts of the Ninth Defendant at the 2023 Derby, the Claimant has had to divert management time away from the normal running of its business at significant cost and detriment to the Clai...		16
40. Due to the remaining threat of disruption, the additional security measures deployed in 2023 were again required at the 2024 and 2025 Epsom Festivals, at further significant cost to the Claimant. The costs of the additional security measures at th...		16
41. As noted at paragraph 60 of Truesdale 1, Surrey Police indicated its support for the interim injunction application, and the Claimant was in constant dialogue with Surrey Police surrounding the 2023 Derby Festival. The Claimant remains in constant...		16
Wider Impact on the Claimant’s Business and the sport		16
42. Disruptive protests have a wide-ranging and serious impact on the Claimant’s business and legitimate commercial interests, and the sport in general. For example, the commercial success and longevity of the Claimant, and horse racing more widely, d...		16
Alternatives to an injunction		17
Non-disruptive protest		17
43. A non-disruptive protest was held at Aintree Racecourse at the Randox Grand National meeting on 5 April 2025. This occurs almost every year, within an area designated for it by the Claimant in conjunction with Merseyside Police. Historically, this...		17
44. Similarly, a ‘peaceful protest’ area was available to those wishing to protest at the Epsom Derby in 2025. This area is located on the roadside immediately over the road from the Racecourse Pavillion/Office Building. The Claimant received no prior...		17
45. I am informed by Mr Allen that five protestors affiliated with Animal Aid stood on the main road outside the Racecourse, holding up pictures purporting to show horses with broken legs. As far as I know, we had no advance notice of their presence. ...		17
46. I note that a similar area was provided to protesters in 2023, but this was not considered a realistic alternative for those intent on disrupting the race.		17
Public order offences		17
47. As far as I am aware, there has been no material change to primary legislation in respect of the public order offences in force since the Final Injunction Order was granted in July 2024. In my view, the statements on AR’s website and social media ...		17
48. On 3 June 2025, Surrey Police confirmed that a trial in respect of those charged for their actions at the Epsom Derby in 2023 would not be heard until September 2028. In my view, the criminal process does not provide a practical alternative to an ...		18
49. I am aware that Epsom and Ewell Borough Council adopted a Public Space Protection Order (PSPO) for the borough on 3 June. This allows police officers to issue fixed penalty notices of £100 for anyone who they have reason to believe has committed a...		18
“5.1 In the Restricted Area a person commits an offence if without reasonable excuse they continue to carry out activities which are prohibited namely;		18
5.1.1. Harassing or intimidating residents, businesses or members of the public.		18
5.1.2. Threatening any person with violence and / or being verbally abusive towards any person.		18
5.1.3. Wearing a piece of clothing with the intent to obscure or hide their identity for the purposes of committing crime and/or anti-social behaviour.		18
5.1.4. Acting, or inciting others to act, in an anti-social manner, that is to say a manner that is likely to cause harassment, alarm or distress to any person.		18
5.1.5. Joining or remaining in a group of 2 or more people which is acting in a manner that is likely to cause harassment, alarm or distress to any person.		18
5.1.6 Consumption of alcohol following a verbal warning by an authorised person to stop. An authorised person includes a Police Constable, Police Community Support Officer, a Council Officer, or any other person authorised by the Council.”		18
50. The Claimant did not receive advance notice of the PSPO. I understand, from discussing with Mr Allen, who informed me of his discussions with Surrey Police, that the PSPO is targeted at people being drunk and disorderly rather than protest activit...		18
51. In any case, I understand that the maximum fine for such offences (other than that which relates to the consumption of alcohol) is £1000. I do not consider this to be a sufficient deterrent for potential protesters, even if they were to be fined u...		18
Byelaws		19
52. I can confirm that there have been no changes to the Byelaws made by the Epsom & Walton Downs Conservators in 2013, pursuant to s. 11 of the Epsom and Walton Downs Regulation Act 1984, which were in place at the time the Interim Injunction and Fin...		19
The Annual Review		19
53. The Claimant made this application pursuant to paragraph 5 of the Final Injunction Order, entitled “Annual Review”, by which Sir Anthony Mann ordered that “The Claimant shall issue an application notice, returnable in the Applications Court on a d...		19
54. The Claimant applies to amend the Annual Review process as ordered by Sir Anthony Mann, to include orders that:		19
54.1 the Claimant shall, if it seeks the continuation of the Injunction, issue an application notice, returnable in the Applications Court on a date within 14 days either side of the anniversary of the order following the first annual review (the “Ann...		19
54.2 if no application is made in accordance with the above, the Injunction will expire on the anniversary of the Annual Review Order and the proceedings will be at an end.		19
55. In doing so, the Claimant seeks a direction that if, in one year’s time, the Claimant no longer seeks to enforce the Injunction, it does not need to make a further application to the Court for a further annual review. This is due to the costs invo...		19
Cross-undertaking		19
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. Exhib...		20
Service		20
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 Fac...		20
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 screenshots of the Claimant’s website.		20
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 a screenshot of the Facebook post.		20
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 a screenshot of the X post.		20
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...		20
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 .		20
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 tha...		20
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 bee...		21
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 ...		21
61. A copy of the Final Injunction Order was also served on Mr Newman by email, exhibited at page 216 of CB1 .		21
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.		21
Statement of Truth		21
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 wit...		21
Signed		22

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