70.
The Applicant will, before 4pm on Monday 22 May 2023, carry out the following steps in respect of the Claim Form, Application Notice and the Witness Statements on which it relies for this application ( “ the Claim Documents ” ):
70.1
post the Claim Documents on its website and the website for the Derby Festival;
70.2
affix copies of the Claim Documents in transparent containers in at least 2 conspicuous locations at each public entrance to the Epsom Racecourse; and
70.3
provide digital copies to AR by email.
71.
If an order granting an injunction is made by the Court, the Applicant will carry out the same steps in relation to the Order, to bring it to the attention of the Second to Eighth Defendants as Persons Unknown. The Applicant believes that the Claim Documents and Order, if an injunction were granted, would be likely to come to the attention of the individuals who affiliate themselves with AR and/or who intend to carry out the acts the Applicant seeks to injunct, in view of the following: As noted above, AR has a strong online presence. The Applicant knows that it has a mailing list by which it contacts individuals who are interested in being involved with its protests. The Applicant also knows that AR publicises its plans widely on social media and across traditional media channels. As such, The Applicant considers it very likely that, once it sends the relevant documents to AR by email, that AR will disseminate it widely, reaching those who intend to be involved in the planned Disruption. The Applicant also considers that individuals intending to take part in protest action are likely to visit the Applicant ’ s website and/or the Epsom Racecourse as part of their planning of the protest action, in the run up to the race days. As such, the Applicant considers it likely that the relevant documents will come to the attention of the Second to Eighth Defendants in these ways. Those attending the Epsom Racecourse on the days in question can see the relevant documents affixed to the public entrances. Accordingly, the Applicant considers it likely that the Application and the Order (if granted) will be brought to the attention of the relevant Persons Unknown, before they proceed to commit any of the acts which the Applicant seeks to injunct. In respect of the First Defendant, the Applicant will effect personal service on him in the usual manner, and also intends to notify him of the Application and of any Order granted, by email.
72.
72.1
72.2
72.3
73.
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