BL-2023-000713 - Bundle for Disposal Hearing

I have worked in horse:racing since 1998 and the staging of the 2023 Grand Natio►ral was, without question, the most challenging day of my career. The disruption caused by AR was significant. Not only did the AR Protestors' actions impact the start of the race, they also: caused the horses waiting to run to become agitated, to which Mr. Sandy Thomson, the trainer of Hill-Sixteen, the horse that tragically died having fallen at the first fence, alluded to in his interviews following the 2023 Grand National [pages 22 to 24 of DW1];

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put the horses, jockeys and themselves in serious danger of harm;

required the Applicant and Merseyside Police to expend an enormous amount of time and resource in dealing with the disruption that occurred on the day, and the fallout of the AP Protestors' actions. There is no doubt that the actions of the AP Protestors diverted the attention of Merseyside Police, along with our Private Security Providers and several of the Racecourse's employees, away from their regular, general safety duties; and

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required the Applicant to spend a considerable amount of money obtaining additional security for the event (see paragraph 16 above).

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The Applicant's Claim

It is my understanding that AR have been vocal in their desire to stop the forthcoming Derby race at Epsom Downs, another of the Applicant's racecourses (the "2023 Derby"). Indeed, the landing page of AR's website states: `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 National' [page 25 of DWI]. Further, as is set out in Ms. Amy Starkey's statement, during recent meetings between AR and the Applicant's representatives, including Ms. Starkey, it is AR's intention to prevent the 2023 Derby from taking place. It appears clear, therefore, that those who caused such significant disruption at the 2023 Grand National are seeking to do exactly the same at the 2023 Derby. It is with this in mind, given that I have had first-hand experience of the impact of the AR Protestors' actions, I fully support the Applicant's claim for an interim injunction against the Respondents.

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Statement of Truth

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or

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