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statement, Mr Knapp concludes that any disruption to racing events presents significant and serious risks to everyone involved, particularly the horses' safety and wellbeing28. significant and serious risks to everyone involved, particularly the horses safety and wellbeing 28 .
The Protestors
33.
Protesters at race meetings often put themselves, and as a result also police and security personnel, at significant risk. In addition to the risk of entering the Racetrack there is also the risk of violence to the protestors should sections of the crowd become hostile to the protestors' actions. There is clear and obvious risk to those security and police staff seeking to apprehend any protestors. I refer, for example, to the statement of PC Hodgkinson, who apprehended the Ninth Defendant and who says that he was in genuine fear for his safety and was scared he was going to be seriously injured29. PC Stevens also stated he was concerned for the safety of individuals who were dealing with the Ninth Defendant and the high-risk situation that the Ninth Defendant had caused39. There is clear and obvious risk to those security and in genuine fear for his safety and was scared he was going to be seriously injured 29 . had caused 30 .
The Public
34.
Should a race be delayed, cancelled, or its safety threatened by protestors, this creates increased risks relating to crowd control and anti-social behaviour.
AdditionalEvent Costs and Organisation
35.
As a result of the threats of trespass and disruption, and the acts of the Ninth Defendant at last year's Derby, the Claimant has had to divert management time away from the normal running of its business at significant cost and detriment to the Claimant. The costs of the additional security measures at the 2023 Grand National and the 2023 Derby are detailed in my First Witness Statement31. Defendant s Derby, the Claimant has had to divert management time away and the 2023 Derby are detailed in my First Witness Statement 31 .
36.
Due to the remaining threat, we anticipate that additional security measures will again be required at the 2024 Epsom Festival, at further significant cost to the Claimant.
37.
As noted in my First Witness Statement, 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. As noted in my First Affidavit, Surrey Police had a significantly increased presence at the Derby Festival in 2023 and carried out a significant operation prior to the festival. Such policing, together with the Claimant's own increased security measures were insufficient, however, to prevent the disruption which occurred. The Claimant remains in close contact with Surrey Police
28 Page 410 of NT4 2° Pages 456-458 of NT4 3° Pages 453-455 of NT4 31 Page 12 of NT4 29 30 31
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