Exhibit JDR2

significant. The racing industry was concerned with this issue when the COVID-19 pandemic hit.

The Protestors

55.

As I have set out above in relation to Ms. Davison, the protesters are putting themselves at significant risk. In addition to the risk of entering the Racetrack there is also the risk of violence to the protestors should sections of the crowd become hostile to the protestors ’ actions.

The Public

56.

Approximately 100,000 people attend the Derby Festival. They attend knowing it is safe and entertaining. Should the race be delayed, cancelled, or its safety threatened by protestors, then there are increased risks relating to crowd control and anti-social behaviour.

Additional Event Costs and Organisation

57.

I have seen the witness statement of Mr. White that refers to the additional measures that were put in place at Aintree in respect of the 2023 Grand National in response to the threat from AR. They include additional security personnel and dogs, at the cost of approximately £70,000 plus VAT.

58.

Additional security measures that the Applicant is putting in place for the 2023 Derby Festival, will cost around £150,000.

59.

In addition to the direct, additional costs of putting on the 2023 Derby Festival, significant organisational and management time has already been (and will continue to be) diverted to operational matters in order to minimise the threat posed by AR. This includes additional discussions with: i) safety personnel; ii) security personnel; iii) the police; iv) the Applicant’s staff; v) the Applicant ’ s commercial partners; vi) the media; vii) suppliers to the Racecourse; viii) jockeys, trainers and owners; ix) the Local Authority; x) the Conservators; and xi) the Applicant ’ s legal team.

60.

The Applicant has been in constant dialogue with Surrey Police surrounding the 2023 Derby Festival. The Police have indicated their support for this injunctive action.

Wider Impact on the Applicant ’ s Business – Management Time

61.

It is not just in relation to the 2023 Derby Festival that the Applicant is having to divert management time away from the normal running of the business of the Applicant. It is wider and includes speaking to all of those listed at paragraph 59 above in relation to

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JDR2 / 22

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