Derby, both the Applicant and BHA provide specialist veterinary teams [Truesdale (DB/30) §34]. Derby, both the Applicant and BHA provide specialist veterinary teams [Truesdale (DB/30) §34] .
43. Finally, the protesters' actions have a significant financial impact on the Applicant, which has been required to spend £150,000 on additional security measures for the Epsom Derby, and extensive management time in discussions with various stakeholders [Truesdale (DB/30) §§58-60]. These include Surrey Police, which is supportive of the Application [Truesdale (DB/30) §60]. 43. Finally, the protesters’ actions have a significant financial impact on the Applicant, stakeholders [Truesdale (DB/30) §§58-60] . These include Surrey Police, which is supportive of the Application [Truesdale (DB/30) §60] .
44. Damages are not an adequate remedy for the Applicant, even assuming there was any source for payment, which is to say the least improbable.
iv. All practicable steps have been taken to notify the Respondents
45. The Applicant has taken all practicable steps to notify the Respondents of the Application, as is required by s. 12(2) HRA if the Respondents are not present or unrepresented. The relevant steps are set out in Section E below.
v. Conclusion on the injunction
46. In light of the submissions above, the Applicant submits that it is just and convenient for the court to grant an interim injunction.
47. It is not clear to the Applicant what damage the Respondents may incur in consequence of an order granting the injunction. However, if the court considers it necessary for the Applicant to provide a cross-undertaking in damages, the Applicant is willing to do so, and has provided its most recent accounts [Truesdale (DB/30) §74] [DB/124-162]. Applicant is willing to do so, and has provided its most recent accounts [Truesdale (DB/30) §74] [DB/124-162] .
E. SERVICE
i. Legal principles
48. CPR 6.15(1) provides that the Court may make an order permitting service of the claim form by an alternative method or at an alternative place, where there is "good claim form by an alternative method or at an alternative place, where there is “ good
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