10.What information will you be relying on, in support of your application? ®the attached witness statement ☒ the attached witness statement
❑ the statement of case ☐
®the evidence set out in the box below ☒ the evidence set out in the box below
If necessary, please continue on a separate sheet. 1. I, JULIAN DIAZ-RAINEY, of Pinsent Masons LLP, 30 Crown Pt, Earl St, London EC2A 4ES, am a solicitor of the Senior Court in England and Wales and a Partner (or, more precisely, a Member) in the firm of Pinsent Masons LLP, solicitors for the Applicant / Claimant; 2. The Claimant in this matter, Jockey Club Racecourses Limited, seeks relief by way of a final injunction prohibiting the Defendants from unlawfully entering Epsom Racecourse for the purposes of disrupting horseracing events held there. The Claimant has already obtained an interim injunction in this regard, by way of an order dated 26 May 2023; 3. Agreed terms for such final injunction have been reached with all named Defendants to the action (i.e. Defendants 1 and 9). The matter proceeds against the unnamed Defendants (2- 8); 4. The Claimant served its evidence in support of the claim, pursuant to CPR 8.5, on 22 May 2023 and further evidence pursuant to the Order of Mr Justice Roth dated 15 March 2024 on 5 April 2024; 5. Since that date, there has been a material change of circumstance which affects the Claimant's evidence, such that it needs to be updated to ensure that the Claimant complies with the requirement to provide full and frank disclosure to the Court; Claimant’s evidence, such that it needs to be updated to ensure that the Claimant complies 1. I, JULIAN DIAZ-RAINEY, of Pinsent Masons LLP, 30 Crown Pl, Earl St, London EC2A 4ES, am a
6. Pursuant to CPR 8.6 (1) (b), if a party to Part 8 proceedings wishes to rely on evidence served other than under CPR 8.5, it must seek the permission of the Court to do so;
7. The Applicant respectfully requests an Order as set out in the enclosed draft for permission to rely on additional witness evidence, which is contained in Schedule 1 of the enclosed draft Order.
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