Exhibit JDR2

Filed on behalf of the Applicant

Witness statement of Nevin Truesdale

Statement No. 1

Date: 22 May 2023

Exhibits: NT1

IN THE HIGH COURT OF JUSTICE THE BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES CHANCERY DIVISION BETWEEN:

JOCKEY CLUB RACECOURSES LIMITED

Applicant

-and-

(1)

DANIEL FRANK PETER KIDBY

(2) PERSONS UNKNOWN INTENTIONALLY OBSTRUCTING THE 7 HORSE RACES ON 2 JUNE 2023 AND 8 HORSE RACES ON 3 JUNE 2023 AT THE LOCATION DESCRIBED BELOW AS THE “EPSOM RACECOURSE” (3) PERSONS UNKNOWN ENTERING THE AREA DESCRIBED BELOW AS THE “RACE TRACK” EXCEPT AT SPECIFIC “CROSSING POINTS” AND WITH

“AUTHORISATION”, AS DESCRIBED BELOW

(4)

PERSONS UNKNO WN ENTERING AND/OR REMAINING ON ANY “CROSSING POINTS” WITHOUT “AUTHORISATION”, AS DESCRIBED BELOW

(5) PERSONS UNKNOWN INTENTIONALLY CAUSING ANY OBJECT TO ENTER ONTO THE “RACE TRACK” WITHOUT “AUTHORISATION”, AS DESCRIBED BELOW (6) PERSONS UNKNOWN ENTERING THE AREA DESCRIBED BELOW AS THE “PARADE RING” WITHOUT “AUTHORISATION”, AS DESCRIBED BELOW (7) PERSONS UNKNOWN ENTERING AND/OR REMAINING ON ANY PART OF THE AREAS DESCRIBED BELOW AS THE “HORSES’ ROUTE TO THE PARADE RING” AND/OR THE “HORSES’ ROUTE TO THE RACE START”, WITHOUT “AUTHORISATION”, AS DESCRIBED BELOW (8) PERSONS UNKNOWN INTENTIONALLY ENDANGERING ANY PERSON AT THE LOCATION DESCRIBED BELOW AS THE “EPSOM RACECOURSE” Respondents

1

JDR2 / 11

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