Exhibit JDR2

annual Scottish Grand National. According to reports in the press, protestors affiliated to AR stormed onto the racetrack, without permission, in an attempt to stop the race from happening 10 (the “ Ayr Incident ” ). The same day, AR ’ s account on Instagram posted a video on their actions at Ayr Racecourse with the message: ‘ Supporters of Animal Rising have made it onto the track at the Scottish Grand National. They are trying to attach themselves to jumps and gates to remain in position, in an attempt to cancel the big race. Last week at Aintree was just the beginning. The Summer of Animal Rising is upon us. ’ 11

43.

44.

I do not know whether the known Respondent was involved in the Ayr Incident.

Doncaster Racecourse

45.

On Saturday 6 May 2023, Doncaster Racecourse, which is located on Bawtry Rd, Doncaster DN2 6BB ( “ Doncaster Racecourse ” ) and is not owned by the Applicant, hosted a racing fixture. The final race of the day was scheduled to commence at 7:55pm but it was delayed after three protesters were spotted sitting in the middle of the racetrack (the “ Doncaster Incident ” ). 12 Later that day, AR ’ s posted an article on its website titled: ‘ Coronation Royal Race Evening Disrupted At Doncaster: Animal Rising Occupy Track. ’ 13

46.

47.

I do not know whether the known Respondent was involved in the Doncaster Incident.

The Incidents

48.

The 2022 Derby, Aintree, Ayr and Doncaster Incidents show a clear and consistent pattern of behaviour and intent on AR ’s part . Further, there has been nothing to suggest that AR ’s campai gn against racecourses is over. Rather, AR ’s website lists three ‘streams of actions… tha t will continue throughout the summer. ’ The second of those ‘streams’ is: ‘ Mass trespass onto animal racing events. ’ 14

Communications Between the Applicant, the Known Respondent and AR

49.

It is my unequivocal view that the known Respondent and AR are seeking to disrupt – and, ultimately, stop – the 2023 Derby. This is based on multiple factors:

10 https://www.dailymail.co.uk/news/article-12002363/Animal-protesters-strike-rush-racecourse-bid-delay-Scottish- Grand-National.html page 58 to 65 of NT1 11 https://www.instagram.com/p/CrV4WMFKFj0/ page 66 to 67 of NT1 12 https://www.mirror.co.uk/sport/horse-racing/animal-rights-protest-doncaster-races-29914141 page 68 to 70 of NT1 13 https://www.animalrising.org/post/coronation-royal-race-evening-disrupted-at-doncaster-animal-rising-occupy-track page 71 to 73 of NT1 14 https://www.animalrising.org/how-we-achieve-change page 74 of NT1

10

JDR2 / 20

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