or are members of AR. As set out below, many of them were wearing AR t-shirts, and AR has widely publicised its involvement in disrupting the Grand National [pages 1 to 7 of DW1]. Therefore, from hereon I shall refer to them as the "AR Protestors". Within this witness statement, I wish to provide details of incidents that affected the 2023 Festival, and in particular the commencement of the Grand National, which took place on Saturday 15 April (the "2023 Grand National"). Save where stated to the contrary, the facts and matters contained in this witness statement are within my own knowledge and are true. Where facts and matters are outside my knowledge, the source is stated, and I believe those facts to be true.
7.
8.
9.
During the course of this statement, I will refer to certain documents, copies of which are exhibited in a paginated bundle marked 'DWI which accompanies this statement.
10.
I make this witness statement in support of the Applicant's claim for an interim injunction against the Respondents.
Background to the 2023 Festival
11.
As part of my role, I have overall responsibility for the security and safe running of all events held at the Racecourse, including the Festival. In advance of racing fixtures, my team and I liaise closely with Merseyside Police, in order to co-ordinate our plans to ensure the safety of those in attendance. 'Safety' involves planning for the safe operation of the whole Festival with due consideration to the substantial number of racegoers attending and those who are part of the Festival itself — e.g., the Applicant's staff, suppliers, owners of horses, trainers and all of their support staff, as well as the horses themselves.
Ahead of a Festival, given the number of those expected to attend, planning and preparation is paramount. This year's event — the 2023 Festival — was no different.
12.
For each Grand National Festival, the Applicant — on behalf of the Racecourse — enters into what is known as an Agreement for Special Police Services, which is a private contract that provides for the provision of special services by a police force — i.e., beyond that which the police would consider necessary to meet their public duty obligations (the "ASPS"). In or around February 2023, we began to hold fortnightly meetings with Merseyside Police to discuss:
13.
13.1
the Racecourse's security plans;
13.2
what Merseyside Police was intending to provide by way of personnel at the 2023 Festival, per the terms of the SPSA and otherwise; and
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