Exhibit JDR2

26.

In 2023, JSO activists carried out a number of disruptive protests at high profile sporting events, presumably with the aim of attracting more attention to its cause. These included: throwing confetti and jigsaw puzzle pieces and/or orange paint and powder at Wimbledon, the Gallagher Rugby Premiership, the Open Championship, the Ashes and the World Snooker Championship 25 . Extinction Rebellion, an international activist organisation that protests about climate and environmental issues published an article on 1 January 2024 which promised “escalating actions and tactics throughout the course of the year” 26 . There is a clear recent history of activist organisations targeting high profile sporting events to seek to attract media attention and further their agenda through disruptive activities. As can be seen from the examples above, the actions taken and sporting events targeted are often not linked in any direct way with the protesters’ purported cause; protesters have targeted a range of high profile sporting events merely to attract attention. As noted in a Reuters article from 21 December 2023 27 , ‘ Sport continues to be a catalyst for protest despite misgivings …. sporting platforms have turned into lightning rods for social activism…Be it athletes or spectators, disobedience or disruption has been the order of the day as they attempt to transcend the boundaries of the arena and convey their views to millions of people worldwide . ’ On this basis, the Claimant continues to be very concerned that the summer of 2024 will see a repeat of the numerous protests that occurred in summer 2023. As set out above, the Epsom Racecourse is particularly vulnerable to trespass and disruption, and absent an injunction, I believe that there is a very real and immediate threat to the safe and smooth operation of the world-famous races hosted there.

27.

28.

29.

30.

The Impact of Trespass and Disruption

31.

As detailed in my First Witness Statement, the disruptive actions of protesters at the Epsom Racecourse have significant and wide-ranging deleterious effects on the following groups.

The Horses and the Jockeys

32.

I refer the Court to the first witness statement of Simon Knapp, the C laimant’s Senior Veterinary Officer for London Region Races, for a detailed assessment of the impact of the threatened action on the horses and jockeys. As detailed in paragraph 15 of that

25 Pages 465-480 of NT4 26 https://extinctionrebellion.uk/2024/01/01/2024-now-we-step-it-up/ - pages 481-486 of NT4 27 https://www.reuters.com/sports/sport-continues-be-catalyst-protest-despite-misgivings-2023-12-21/ - pages 487-489 of NT4

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JDR2 / 8

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