Filed on behalf of the Claimant / Applicant First Affidavit of N Truesdale Sworn before: Edward Gardiner Affidavit No. 1 Date Sworn: 1August 2023 Exhibits: NT2 NT3 Affidavit No. 1
person at the Epsom Racecourse. References to pages within the Injunction Application bundle are marked in the following format: "IA page x". Application bundle are marked in the following format: “ IA page x ”.
5.2
A copy of the Applicant's authorities bundle used at the Injunction Application. A copy of the Applicant’s authorities bundle used at the Injunction Application.
6.
For completeness, I enclose the Applicant's skeleton argument for the Injunction Application at pages 21-36 of NT2. For completeness, I enclose the Applicant’s skeleton argument for the Injunction
7.
Unless otherwise stated I adopt the definitions in the Order, thereafter in my first Witness Statement dated 22 May 2023.
Background
8.
The background to this matter has been set out extensively in the first witness statements of:
8.1
myself (IA pages 30-162);
Amy Starkey, Managing Director of the Applicant (IA pages 163-187);
8.2
Dickon White, Aintree and North-West Regional Director for the Applicant (IA pages 188-221);
8.3
Simon Knapp, Senior Veterinary Surgeon for London Region Races at the Applicant (IA pages 222-226); and
8.4
8.5
Julian Diaz-Rainey of the Applicant's solicitor (IA pages 227-252). Julian Diaz-Rainey of the Applicant’s solicitor (IA pages 227-252).
9.
In summary, the Applicant owns Epsom Racecourse, which hosts the Epsom Derby Festival, a horse-racing festival set across 2 days each year including the prestigious race the Epsom Derby on the Saturday. In response to a threat from the group Animal Rising to disrupt the Derby Festival, as it had done at the Grand National, the Applicant issued proceedings against the First to Eighth Defendants, applying concurrently for an interim order to prohibit the Derby Festival from being disrupted.
The Order
10.
The Injunction Application was successful and resulted in the provision of the Order.
11.
The Order (as is set out in its terms) ordered that the First Defendant as named, plus certain categories of 'persons unknown' defendants (the "Persons Unknown certain categories of ‘persons unknown’ defendants (the “ Persons Unknown
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