Exhibit JDR2

members of AR (beyond the First and Ninth Defendants), how many there may be, or what their intentions are in respect of horse racing. At least, as of last year, it had been suggested that there were 1000 active members. Furthermore, as seen last year in respect of the actions of the Ninth Defendant, individuals affiliated with AR may act alone. I consider that despite AR’s statement, therefore, there remains a threat that individual protesters may seek to enter onto the track at the Epsom Racecourse and disrupt the races. Just one individual doing so is sufficient to pose a significant risk to all those in attendance. Furthermore, AR continues to recruit new members via its website, https://www.animalrising.org/, where it encourages people to: i) join weekly talks via Zoom, to learn about the group; ii) attend training courses run by AR, to engage in ‘non - violence training’ ; and iii) sign-up for its local groups. In particular, the ‘About Us – Who is Animal Rising’ section of AR’s website states that ‘ This summer will be the summer of Animal Rising ’ , and that the organisation ’s ‘ campaigns this year are going to be huge ’ . AR states that it will be ‘freeing animals, occupying farms, and disrupting cruel and ou tdated animal racing events’ 23 . The group emphasises the need to challenge purported exploitation of animals in various industries, including horse racing. Similarly, under the heading ‘How we achieve change’, AR’s website sets out the organisation’s planned protests for summer 2024, which include at point 2 ‘ Mass trespass onto animal racing events. ’ It states, ‘ As a nation of animal lovers it is about time we put these cruel, outdated practices under the spotlight and bring them to an end. There are more fun ways to spend a weekend than watching animals die, and as a society we will find ways to love animals without harming t hem’ 24 . In short, I believe that there remains a threat that animal rights protesters, whether or not affiliated with AR, may be inspired by AR’s previous actions and ongoing messaging on its website, and seek to disrupt the races at Epsom. As set out above, the nature of the racecourse at Epsom makes it very difficult to secure from those intending to trespass on the tracks. Moreover, the Derby in particular is, of course, one of the best attended, most famous and widely broadcast, horse races in the world and a key target for activist groups seeking to attract media attention.

22.

23.

Wider protest action at Sporting Events

24.

Further to the above, I believe that there remains a threat that other activists, not only those purportedly driven by animal rights concerns, will disrupt the races. Just Stop Oil ( “JSO” ) is an environmentalist activist group that says it wants the UK government to commit to ending new fossil fuel licensing and production.

25.

23 https://www.animalrising.org/who-are-animal-rising - pages 493-496 of NT4 24 https://www.animalrising.org/how-we-achieve-change - pages 497-498 of NT4

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