Exhibit JDR2

approximately 100 protestors affiliated with AR (the “ AR Protestors ” ) began scaling the 10ft fence that surrounds Aintree ’ s perimeter ( “ the “ Perimeter Fence ” ). The AR Protestors used ladders and various other tools in an attempt to gain access to the racecourse. For the avoidance of doubt, the AR Protestors had no legal right to access the Applicant ’ s property. The police and members of Aintree ’ s security team were engaged in an ongoing battle with the AR Protestors for a substantial period of time. Despite this, several of the AR Protestors were successful in gaining access to the racecourse and managed to get onto the racetrack (the “ First Unauthorised Access ” ); and a further three AR Protestors were able to gain access to the racetrack via the Embankment Enclosure, which contains one of the main spectator stands at Aintree. It is my understanding that these individuals had purchased tickets for the 2023 Grand National. Prior to the commencement of the race, they had accessed the racetrack by running underneath the fencing that skirts its edge. It is my understanding that these individuals were attempting to reach the second fence, over which the horses jump, in order to glue themselves to the fence (the “ Second Unauthorised Access ” ). For the avoidance of doubt, the AR Protestors had no legal right to access the racetrack. As a result of the First and Second Unauthorised Accesses (together the “ Aintree Incidents ” ), the start of the 2023 Grand National was delayed. The consequences of the AR Protestors ’ actions, and further information on what occurred, are set out in Mr. White ’ s witness statement that supports this application.

38.1

38.2

39.

40.

I am confident that those involved in the Aintree Incidents were affiliated with AR as:

40.1

several of the AR Protestors were wearing AR t-shirts; and

40.2

AR has widely publicised its involvement in disrupting the 2023 Grand National. 8

41.

In respect of the known Respondent, AR ’ s account on Instagram posted a video of the known Respondent on 17 April 2023 with the message: ‘ Hear from Animal Rising co- founder Dan Kidby about his actions on the track at Aintree... ’ 9 In the video, the known Respondent states: “ I was the person in the grey suit who made his way onto the tracks to try and stop the Grand National from happening. ” This suggests that the known Respondent was involved in the Second Unauthorised Access.

Ayr Racecourse

On Saturday 22 April 2023, Ayr Racecourse, which is located on Whitletts Rd, Ayr KA8 0JE ( “ Ayr Racecourse ” ) and is not owned by the Applicant, hosted the

42.

8 https://www.dailymail.co.uk/news/article-11976413/Grand-National-DELAYED-Animal-Rising-protesters-storm-Aintree- course.html page 29 to 57 of NT1 9 https://www.instagram.com/p/CrJfJV9Klo7/ page 1 of NT1

9

JDR2 / 19

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