Exhibit JDR2

independent board (the Horse Welfare Board) that advise and lobby on further improvements to equine welfare, holding the industry to account.

33.

None of the fixtures held annually in Britain could take place unless key BHA welfare criteria have been satisfied. From a purely commercial point of view, we would not have a business if safety standards were not being met. In relation to the Derby specifically, as I understand from discussing with Amy Starkey the Managing Director of Applicant, neither I nor Amy (during our combined 28 years of employment with the Applicant) has ever been questioned by the media in relation to the safety of horses at the Derby. It is a flat race and I understand that no horse has died at the Derby since 2006 – 16 runnings. On the day of the Derby, there is a full veterinary team on site, provided by the Racecourse. Further, the BHA also provide their own veterinary team. These teams are present at every point during the horses ’ journey and remain in close proximity throughout. They provide a high level of veterinary care.

34.

Incidents Involving the Known Respondent and/or AR

2022 Derby

The 2022 running of the Derby took place on 2 June 2022 (the “ 2022 Derby ”).

35.

36.

Ahead of the 2022 Derby, approximately six protestors affiliated to the activist group ‘Animal Rebellion’ evaded the Racecourse ’s security and ran on to the Racetrack. 5 According to Animal Rebellion ’ s website, the purpose was to ‘ disrupt the race. ’ The group also called for ‘ an end to horseracing ’ 6 (the “ 2022 Derby Incident ” ). It is my understanding that Animal Rebellion and AR are one and the same organisation, and that Animal Rebellion simply changed its name to AR in or around in April 2023. 7 The Applicant also owns Aintree Racecourse, which is located on Ormskirk Rd, Aintree, Liverpool L9 5AS ( “ Aintree ” ). I was at Aintree on Saturday 15 April 2023, where the Grand National was scheduled to commence at 5:15pm (the “ 2023 Grand National ” ). Shortly prior to the commencement of the race, however, the following incidents occurred:

37.

Aintree Racecourse 38.

5 https://www.theguardian.com/world/2022/jun/04/animal-rebellion-protesters-run-on-to-track-before-epsom-derby pages 19 to 20 of NT1 6 https://animalrebellion.org/protestors-disrupt-epsom-derby-in-a-call-for-an-end-to-animal-exploitation/ pages 21 to 24 of NT1 7 https://plantbasednews.org/news/activism/animal-rebellion-rebrand-rising/ pages 25 to 28 of NT1

8

JDR2 / 18

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