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SECOND WITNESS STATEMENT OF NEVIN TRUESDALE
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I, NEVIN TRUESDALE, of the Jockey Club Racecourses Limited, 21-27 Lambs Conduit St, London, WC1N 3NL, WILL SAY as follows: I, NEVIN TRUESDALE , of the Jockey Club Racecourses Limited, 21-27 Lambs Conduit St, London, WC1N 3NL, WILL SAY as follows:
1.
This is my second witness statement in support of the claim and I am duly authorised by the Claimant to make this statement on its behalf. My first witness statement is dated 22 May 20231 and I refer the Court to, and adopt as part of my evidence for the forthcoming hearing, that statement. I also refer the Court to, and adopt as part of my evidence for the forthcoming hearing, my first affidavit dated 1 August 20232. I adopt the defined terms set out in my first witness statement and my first affidavit. 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 matters are true to the best of my knowledge and belief. There is now produced and shown to me marked exhibit "NT4" 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 "NT4". dated 22 May 2023 1 and I refer the Court to, and adopt as part of my evidence for the evidence for the forthcoming hearing, my first affidavit dated 1 August 2023 2 . I adopt
2.
3.
Background
4.
The background to this matter has been set out extensively in:
my first witness statement3; my first witness statement 3 ;
4.1
the first witness statement of Amy Starkey, Managing Director of the Claimant4; the first witness statement of Amy Starkey, Managing Director of the Claimant 4 ;
4.2
4.3
the first witness statement of Dickon White, Aintree and North-West Regional Director for the Claimants; for the Claimant 5 ;
4.4
the first witness statement of Simon Knapp, Senior Veterinary Surgeon for London Region Races at the Claimants; Region Races at the Claimant 6 ;
Pages 1-133 of NT4 2 Pages 134-346 of NT4 3 Pages 1-133 of NT4 4 Pages 347-371 of NT4 6 Pages 372-405 of NT4 1 2 3 4 5
532
2
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