• Pros:
• Main defendant in the case. 
• Gives Hathaway a chance to defend "money issues"
• Can explain why he was on the trip.
  
• Paints a broader brush of what all occurred. 
• Talks about medical issues with Lee
  
• Cons:
• Overlap between Him & Reggie Rogers. 
• Better to call Rogers. 
• "Dollar before safety"
• Wasn't in charge of the trip.

Quincy Montgomery:

• Pros:
• Called if Plaintiff calls River Tran. Refutes if called.
  
• Cons:
• Only really applicable if River Tran is called.
• Not that great of a witness.
  

Reggie Rogers:

• Pros:
• Was in charge of the trip.
  
• Cons:

Jordan Nelson

• Pro:
  
• Weather did play a role. 
• Professional Opinion was that Neptune was good about the weather.
  
• Con:
• Making a TON of money. 
• Doesn't really add much
• Weather can be a pro. 

Defense Themes:

• Lee Allen owed a duty of care to himself & didn't follow that.
  
• Exceptional situation: (Neptune didn't use Buddy system, but they knew what they were doing)
• Lying. Can't lie on a challenging dive.
  
• Basic Themes:
  
• Lee Allen was reckless.
  
• Neptune was not.  
• No on put a gun to Lee's head.
  
• Foolishness.
  
• Hypertension is huge.
  
• Lee went to 2nd level to ship. (his decision)