confirmation that the First Respondent downloaded the documents attached to the aforementioned email at 17:24 on 22 May 2023.
At approximately 18:30 on 22 May 2023 Animal Rising ("AR") issued a response to the injunction application on its websitel, which is at page 4 of JDR1. The response is almost entirely one quote attributed to the First Respondent, indicating that he had read the claim documents. I enclose an email from the Applicant to the First Respondent from approximately 18:36 on 22 May 2023 at pages 5 - 6 of JDR1, which amongst other things alerted the First Respondent to the application. At approximately 21:12 on 22 May 2023 Kerri Waters of AR emailed the Applicant to say amongst other things that "Iam also very grateful thatyoureached out toDan about the injunction and explained the reasons behind it." (page 7 of JDR1). I am also very grateful that you reached out to Dan about the injunction and explained the reasons behind it 7 of JDR1). At approximately 18:30 on 22 May 2023 Animal Ri AR injunction application on its website 1 , which is at page 4 of JDR1. The response is
8.
9.
10.
Service of the claim documents on the Second to Eighth Respondents
11.
I enclose at pages 8 - 13 of JDR1 six photographs with details of their metadata taken between 15:48 and 16:04 on 22 May 2023. They show two envelopes containing the Sealed Application Notice, Sealed Claim Form, Response Pack and the Witness Statements 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. I am instructed that the Sealed Application Notice, Sealed Claim Form, Response Pack and the Witness Statements (save for the exhibit to the witness statement of Nevin Truesdale (Exhibit NT1)) were posted on the websites for Epsom2 and the Applicant3 at 16:10 on 22 May 2023. Both of those news articles linked to a page where the claim documents could be downloaded (https://wvvw.thejockeyclub.co.uk/the-derby-festival- 2023/) (page 18 of JDR1). Exhibit NT1 was added at 17:02 on 22 May 2023. In addition to the above, the Applicant also posted announcements on their social media channels, including twitter4 and facebook5, at 16:38 on 22 May 2023, with links to a press release (pages 21 - 22 of JDR1). channels, including twitter 4 and facebook 5 , at 16:38 on 22 May 2023, with links to a press release (pages 21 - 22 of JDR1 ). Truesdale (Exhibit NT1)) were posted on the websites for Epsom 2 and the Applicant 3 at documents could be downloaded (https://www.thejockeyclub.co.uk/the-derby-festival-
12.
13.
I httos://www.animalrising.org/oost/jockey-club-injunction-animal-rising-response page 4 of JDR1 2 httos://www.thejockeyclub.co.uk/eosom/media/news/ pages 14 - 15 JDR1 3 httos://www.thejockeyclub.co.uk/the-racing/racing-news/ pages 16 —17 of JDR1 1 https://www.animalrising.org/post/jockey-club-injunction-animal-rising-response page 4 of JDR1 2 https://www.thejockeyclub.co.uk/epsom/media/news/ pages 14 15 JDR1 3 https://www.thejockeyclub.co.uk/the-racing/racing-news/ pages 16 17 of JDR1 4 https://twitter.com/TheJockeyClub/status/1660671511781416961?cxt=HHwWgoC9xZ_88YsuAAAA page 19 of JDR1 5 https://m.facebook.com/story.php?story_fbid=6533648479999113&id=137224449641580 page 20 of JDR1 4 httos://twitter.comiTheJockeyClub/status/1660671511781416961?cxt=HHwWgoC9x2 88YsuAAAA page 19 of JDR1 6 https://m.facebook.com/story.php?story fbid=6533648479999113&id=137224449641580 page 20 of JDR1 952
140242150.1\645003
3
413
Made with FlippingBook interactive PDF creator