Exhibit JDR2

49.1

AR have clearly set out their intentions on their own website. The heading on their landing page states: ‘ Take action for all life: disrupt the Epsom Derby - join us on the tracks. ’ In addition, it says: ‘ Join us on the tracks of the Epsom Derby! We'll be disrupting the Epsom Derby to continue the conversation we started at the Grand National ’ 15 ; and as is set out in detail in Ms. Starkey ’ s witness statement, during a meeting on 11 May 2023 between AR, including the known Respondent, and the Applicant ’ s representatives, including Ms. Starkey (the “ 11 May Meeting ” ), the known Respondent set out AR ’ s clear intent that they would disrupt the 2023 Derby in an attempt to stop the race from happening.

49.2

50.

As detailed in Ms. Starkey ’ s statement, the Applicant made every effort to dissuade the known Respondent and AR from pursuing such action, including:

50.1

offering them the opportunity to have a dedicated position on-site to hold a peaceful protest; and

50.2

describing the potential dangers of their proposed disruption, not just to the horses, but to the jockeys and the general public.

51.

Notwithstanding this, it is my understanding that the known Respondent and AR remain committed to their plans to disrupt the 2023 Derby.

The Impact of the known Respondent and AR ’ s Actions and Threatened Actions on the Derby and Beyond

52.

The impact of the known Respondent and AR ’s actions and threatened actions are significant and span a number of issues and stakeholders as I set out below.

The Horses and the Jockeys

53.

The impact of the threatened action on the horses and jockeys is profound. In this regard I refer the Court to the first witness statement of Simon Knapp, the Senior Veterinary Officer for London Region Races, at the Applicant.

The Breeding Industry

54.

It is no exaggeration to say that the Derby defines the breed, it is not just about the racing. It is only 3-year-old colts that race in the Derby and the majority of the leading horses are often retired to stud after that season. If the Derby was cancelled the effect not just on those horses, but on the whole breeding and racing industry would be very

15 https://www.animalrising.org/ page 76 to 79 of NT1

11

JDR2 / 21

Made with FlippingBook - professional solution for displaying marketing and sales documents online