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
14.6
"Epsom Racecourses" means the area where the Claimant holds Racing Fixtures, within the red line marked on the Plan. “Epsom Racecourses” means the area where the Claimant holds Racing Fixtures,
14.7
The "Plan" means the aerial photographs of the Epsom Racecourse and the markings thereupon, appended to the Order. The “Plan” means the aerial photographs of the Epsom Racecourse and the markings
15.
The Order contained a penal notice as follows:
IF YOU THE WITHIN NAMED DEFENDANTS OR ANY OF YOU DISOBEY THIS ORDER OR INSTRUCT OR ENCOURAGE OTHERS TO BREACH THIS ORDER YOU MAY BE HELD TO BE IN CONTEMPT OF COURT AND MAY BE IMPRISONED, FINED, [OR] HAVE YOUR ASSETS SEIZED ANY OTHER PERSON WHO KNOWS OF THIS ORDER AND DOES ANYTHING WHICH HELPS OR PERMITS THE DEFENDANTS TO BREACH THE TERMS OF THIS ORDER MAY ALSO BE HELD IN CONTEMPT OF COURT AND MAY BE IMPRISONED, FINED OR HAVE THEIR ASSETS SEIZED
Service of the Claim Documents and Order
16.
Paragraph 3 of the Order sets out the steps that the Claimant had to undertake to effect service of the Claim Documents on the Persons Unknown Defendants. For ease of reference these steps were:
16.1
Posting digital copies of the Claim Documents on its website and Facebook page;
16.2
Affixing sealed copies of the Claim Documents in transparent containers in at least 2 conspicuous locations at public entrances to the Epsom Racecourse; and
16.3
Providing digital copies to the organisation Animal Rising by email.
Posting a digital copy of the Claim Documents on its website andFacebook page
17.
On 22 May 2023 at 16:10 the Applicant posted the Claim Documents to both the website relating to Epsom Downs (i.e., www.thejockeyclub.co.uk/epsom) and its own website (i.e., www.thejockeyclub.co.uk). I enclose at pages 37-41 of NT2 screenshots of both websites along with a screenshot of the displayed Claim Documents at page 41 of NT2.
Affixing sealed copies of the Claim Documents in transparent containers in at least 2 conspicuous locations at public entrances to the Epsom Racecourse
18.
Enclosed at pages 42-47 of NT2 are six photographs with details of their metadata taken between 15:48 and 16:04 on 22 May 2023. They show two envelopes contained the Claim Documents at each of the two public entrances to the Epsom Downs Racecourse. This information has been provided to me by Simon Durrant, the General Manager of Kempton Park Racecourse.
Providing digital copies to the organisation AnimalRising by email
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