Exhibit JDR2

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FIRST WITNESS STATEMENT OF NEVIN TRUESDALE

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I, NEVIN TRUESDALE , of the Jockey Club Racecourses Limited, Sandown Park Racecourse, Portsmouth Road, Esher, Surrey, England, KT10 9AJ, WILL SAY as follows:

1.

I am the Group Chief Executive of the Applicant. I have held this position since the end of August 2020.

2.

I joined the Applicant in 2013 as Group Finance Director from Centrica, where I was Fina nce Director for British Gas’s Residential Energy division. I previously worked at The AA and Ernst & Young and I am a graduate of the University of Cambridge. I am a qualified Chartered Accountant since 1998 and a Full Member of the Institute of Chartered Accountants in England and Wales. I report to the Board (in the Applicant ’ s case, known as the ‘ Stewards ’ ) and have overall management responsibility for the business of the Applicant, which includes all aspects of the Group ’ s activity including the racecourses operations, gallops, national stud and racing welfare. I am also a non-executive director of Sports United Against Dementia, a charity with senior leaders across the sports industry using their contacts and influence to find a cure and fundraise for dementia.

3.

4.

I am duly authorised by the Applicant to make this statement on its behalf and in support of its application for injunctive relief.

5.

Unless stated otherwise, the facts and matters set out in this Witness Statement are within my knowledge and are true. Where any facts or matters are not within my own knowledge, the source of the information is identified and those facts and matters are true to the best of my knowledge and belief. There is now produced and shown to me marked exhibit "NT1" a bundle of true copy documents to which I refer in the course of this Witness Statement. Save where stated otherwise, references below to page numbers are to the pages of exhibit "NT1".

6.

The Parties

7.

The Jockey Club ’ s (the Applicant ’ s parent company incorporated by Royal Charter) existence dates back to the Eighteenth Century. The Applicant is now the largest commercial horseracing organisation in the United Kingdom. It owns and operates a number of well-known racecourses, as well as owning and exploiting the commercial

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