Exhibit JDR2

Festival from various points around the racecourse. Aerial photographs of Epsom Racecourse are included in NT1 14 .

9.

Further, due to the geography of Epsom Racecourse it is not possible to see the entirety of the racecourse from any ground level point on the racecourse. Due to this, there are several points on the course where protesters can enter the racecourse and will not have visibility of the start line of the racecourse to see whether the race has begun.

10.

This creates a greater level of danger and risk for the protesters who decide to enter the racecourse which is unique to Epsom Racecourse.

Animal Rights protests

11.

As detailed in my first witness statement at paragraphs 35 to 48 15 , my first affidavit at paragraphs 55 to 58 16 , and the witness statement of Dickon White at paragraphs 19 to 27 17 , animal rights protesters have organised several protests at horse racing events with the aim of causing disruption and attracting media attention to further their cause. Ahead of the 2022 Derby, six protestors affiliated with the protest group Animal Rising (“ AR ”), at the time known as Animal Rebellion, evaded the Racecourse’s security and ran on to the Racetrack. The First Defendant is the co-founder of AR and the Ninth Defendant is affiliated with the group. In 2023, protesters affiliated with AR planned and instigated protests at the 2023 Grand National, Ayr Racecourse and Doncaster Racecourse. Further, and in the knowledge of the Interim Injunction Order, the Ninth Defendant entered the racecourse at the 2023 Derby, intentionally disrupting the race. This demonstrates a pattern of behaviour by animal rights activists with a particular focus to disrupt horse racing events. I enclose a video featuring Alex Lockwood, a co- founder of AR, who looks back on AR’s ‘achievements’ in 2023 18 . He champions protest action at the 2023 Grand National and the 2023 Derby in spite of the Interim Injunction Order. Mr Lockwood states that the Ninth Defe ndant’s actions at the 2023 Derby created AR’s ” biggest ever press day ” and helped the group to further its aims and agenda. It is clear therefore that, despite such actions being in many cases criminal and, as with the conduct of the Ninth Defendant in this matter, a contumelious breach of a court order, they have nevertheless been celebrated by animal rights protesters.

12.

13.

14.

15.

14 Pages 28-33 of NT4 15 Pages 8-10 of NT4

16 Pages 147-148 of NT4 17 Pages 376-378 of NT4 18 https://www.youtube.com/watch?v=ymF75WOcNUs - page 464 of NT4

4

JDR2 / 5

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