Suggested pre-reading (with a time estimate of1 hour): (1) the Applicant's skeleton argument, (2) the draft Order and Plan, (3) the witness statements of Nevin Truesdale, Amy Starkey, Dickon White, Simon Knapp, and Julian Diaz-Rainey. References in theformat113B/41 are to page numbers in the Documents Bundle, and (ABP] to page numbers in the Authorities Bundle, provided by the Applicant. References in the format [DB/*] are to page numbers in the Documents Bundle, and [AB/*] to References in theformat e.g. (Truesdale (D/B9 §41 are to the witness statement of the named individual, thefirst page of the witness statement in the Documents Bundle, and the relevant paragraph. References in the format e.g. [Truesdale (D/B*) §*] are to the witness statement of the named Suggested pre-reading (with a time estimate of 1 hour): (1) the Applicant’s skeleton argument,
A. INTRODUCTION
1. This is an application for an interim quia timet injunction to restrain one known and other unknown persons from disrupting horse races at Epsom Racecourse ("the Application"). The injunction is sought, in particular, to restrain protesters from disrupting the Oaks meeting on 2 June and the Epsom Derby meeting on 3 June 2023. 2. The terms of the injunction sought are set out in the draft Order [DB/14]. These intend to prevent protesters from trespassing on various parts of the Applicant's land and/or unlawfully interfering with the Applicant's statutory right to hold racing fixtures (as set out in Section B below). 1. This is an application for an interim quia timet injunction to restrain one known and other unknown persons from disrupting horse races at Epsom Racecourse (“ the Application ”). The injunction is sought, in particular, to restrain protesters from 2. The terms of the injunction sought are set out in the draft Order [DB/14] . These intend to prevent protesters from trespassing on various parts of the Applicant’s land and/or unlawfully interfering with the Applicant’s statutory right to hold racing fixtures (as
3. Attached to the draft Order is a set of aerial photographs identifying the areas of the Epsom Racecourse the Applicant seeks to protect ("the Plan"; also at [DB/57-62]). Epsom Racecourse the Applicant seeks to protect (“ the Plan ”; also at [DB/57-62] ).
4. The Applicant is the largest commercial horseracing organisation in the UK. It is the freehold owner of the Epsom Downs, and of the Epsom Racecourse (marked with a red line on the Plan) [Truesdale (DB/30) §7-8, 18] [DB/56]. 5. Daniel Frank Peter Kidby ("R1") describes himself as the co-founder of Animal Rising, a collective of individuals with a shared purpose said to be focused on animal welfare ("AR") [Truesdale (DB/30) §10] [DB/173]. AR is believed to have some 1,000 active participants [DB/46]. It is clear that R1, together with AR, disrupted the races at the Grand National on 15 April 2023. AR has publicly shared its plans to disrupt the red line on the Plan) [Truesdale (DB/30) §7-8, 18] [DB/56] . 5. Daniel Frank Peter Kidby (“ R1 ”) describes himself as the co-founder of Animal Rising, (“ AR ”) [Truesdale (DB/30) §10] [DB/173] . AR is believed to have some 1,000 active participants [DB/46] . It is clear that R1, together with AR, disrupted the races at the
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