rights associated with those courses and the races which they host. It is governed by a Royal Charter and all of its profits are recycled into the sport. The Applicant runs over 340 racing fixtures a year across 15 different racecourses. Queen Elizabeth II was a patron of both the Applicant and the Thoroughbred Breeders' Association. The Applicant is a limited liability company registered in England and Wales with the number 02909409 and whose registered address is Sandown Park Racecourse, Portsmouth Road, Esher, Surrey, England, KT10 9AJ. It has at all material times carried on the business of owning and operating horse racecourses, organising race meetings at such racecourses, owning and exploiting the commercial rights associated with such meetings and racecourses and related activities. was a patron of both the Applicant
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The Applicant employs more than 600 permanent staff and more than 3,000 people on an event basis throughout the UK across a diverse range of roles.
The known Defendant/Respondent is the co-founder of Animal Rising', an animal activist movement based in the United Kingdom ("AR"). It is my understanding that AR is not a corporate entity and that it has no particular hierarchical structure. Rather, AR is a collection of persons who all share a common purpose. I know very little of the other members of AR, or how many there may be, save that: i) the group has large followings on each of its social media accounts (65.5 thousand followers on Instagram, and 23.7 thousand on Twitter; and ii) it has been suggested to the Applicant that the group has over 1,000 active participants2. At the time of signing this witness statement, it appears that AR recruits new members via its website, https://www.animalrising.org/, where it encourages people to: i) join weekly talks, via Zoom, to learn about the group; ii) attend training courses run by AR, to engage in 'non-violence training'; and iii) sign-up for its local groups. In respect of the latter, those interested are asked to complete a registration form that asks for, inter alia, the person's name, their email address, their mobile phone number and, particularly relevant for the purposes of this application, whether the interested individual would like to disrupt the races at Epsom Derby (03/06).'3 Further, at the time of writing this, there is a banner at the top of the AR website stating "TAKE ACTION FOR ALL LIFE: DISRUPT THE EPSOM DERBY. JOIN US ON THE TRACKS". Clicking on the link behind the wording "JOIN US ON THE TRACKS" takes one to a forma which states inter alia "Join us on the tracks of the Epsom Derby! We'll be disrupting the Epsom Derby to continue the conversation we started at the Grand The known Defendant/Respondent is the co-founder of Animal Rising 1 , an animal activist movement based in the United Kingdom ( AR ). It is my understanding that AR Applicant that the group has over 1,000 active participants 2 . to engage in non-violence training ; and iii) sign-up for its local groups. In respect of the latter, those interested are asked to complete a registration form that asks for, inter alia , the persons name, their email address, their mobile phone number and, individual would like to disrupt the races at Epsom Derby (03/06) . 3 Further, at the time of writing this, there is a banner at the top of the AR website stating TAKE TRACKS . Clicking on the link behind the wording JOIN US ON THE TRACKS takes one to a form 4 which states inter alia Join us on the tracks of the Epsom Derby! We'll
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https://www.instagram.com/p/CrMV9K1o7/ - page 1 of NT1 2 https://www.dailymaiLco.uk/news/article-12106435/MiIitant-animal-rights-activists-vow-sabotage-Epsom-Derby-target- unpoliceable-racetrack.html - page 2 of NT1 3 https://www.animalrising.org/get-involved pages 3 - 8 of NT1 4 https://docs.google.com/forms/d/e/1FAIDCILSfvckRfv8DgaBBphatMuh98Y2X UKU6 Nwohz9iLS1uWJm1RA/viewform pages 9-11 of NT1 542 3 1 https://www.instagram.com/p/CrJfJV9Klo7/ - page 1 of NT1 2 https://www.dailymail.co.uk/news/article-12106435/Militant-animal-rights-activists-vow-sabotage-Epsom-Derby-target- 3 4 https://docs.google.com/forms/d/e/1FAIpQLSfvckRfv8DgqBBphqtMuh98Y2X_UKU6_Nwohz9jLS1uWJm1RA/viewform
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