Exhibit JDR2

National. Be one of those to make history and achieve meaningful change for all life, join us on the tracks . ”

12.

What is known about AR and the known Respondent is that they are actively seeking to disrupt horseracing. This is abundantly clear from the website and social media per the above and: the actions of AR and the known Respondent at Aintree Racecourse (operated by the Applicant) ahead of the 2023 Grand National, which took place on Saturday 15 April 2023 (the “ 2023 Grand National ” ). I briefly address the incidents that took place at the 2023 Grand National at paragraphs 38 to 41 below, but a more detailed account is provided in the witness statement of Dickon White, the Applicant ’ s Aintree and North- West Regional Director, who manages Aintree Racecourse and who witnessed the actions of AR and the known Respondent first hand; the meetings and conversations the Applicant ’ s representatives have had with the known Respondent and members of AR, during which it has been made clear to the Applicant that AR ’ s intention is to disrupt horseracing and to prevent races from going ahead, in particular a forthcoming race at Epsom Downs Racecourse, Tattenham Corner Rd, Epsom KT18 5LQ (the “ Racecourse ” ). I briefly address these communications at paragraphs 49 to 51 below, but a more detailed account is provided in the witness statement of Amy Starkey, the Applicant ’ s Regional Director – East, who has had several interactions with the known Respondent and AR; and A Mail on Sunday article dated 21 May 2023 (page 2 of NT1), amongst other things, reports that AR will try to break on to the Racetrack in an attempt to delay or cancel the Derby.

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12.3

The Racecourse and Derby Festival

13.

In 1994, the Applicant purchased the Racecourse. The key race in the calendar at the Racecourse is the Derby (also known as the Epsom Derby) which takes place on the first Saturday of June each year (the “ Derby ” ). The Derby was first run in 1780 and is widely regarded as the Wor ld’ s most prestigious flat horse race. It is known as the People ’ s Race as it embraces people from all walks of life offering free access to the Derby from the Epsom Downs. Queen Elizabeth II rarely missed a Derby.

14.

15.

The Friday before the Derby is known as Ladies Day and features the Oaks, another of Britai n’s five classic races. Both days are known together as the “ Derby Festival ” .

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