Main point: Andy Allen knew about Lee’s struggles and was in the best position to observe him as his dive partner, and yet did not inform Neptune about these struggles despite multiple opportunities to do so.

Main point: Lee Allen and Andy Allen lied about their experience and deceived Neptune about Lee’s health.

Sub-main point: the weather was perfect until after the divers entered the water.

Mr./Ms. Allen, I understand this is a difficult subject for you to discuss. If you need to pause at any point, please just let me know. I need to ask you a few questions about Lee.

• You would describe Lee as a daredevil?
• Lee did once say that he was not afraid of risk, yes?
• You and Lee earned the same certification, right?
• And you would describe Lee as a competent diver?
• Now, Lee was the one who initially suggested the Hepburn expedition?
• Lee had to convince you to do the expedition, correct?
• He mentioned Neptune’s triple-1 rating with the Superior Business Bureau?
• Lee also mentioned Neptune had never been sued in Midlands, yes?
• Now, in addition to this research, you had a videoconference with Hayden Hathaway?
• Hathaway really impressed you?
• Hathaway seemed like a scuba diver first and a businessperson second, yes?
• Now, Hathaway made it clear that the Hepburn was safe if you had the necessary experience, right?
• You told Hathaway you had completed 50 dives, correct?
• Ms. Allen, that was a lie, yes?
• Now Hathaway also asked about wreck dives?
• Lee told Hathaway that you did a wreck dive last year, yes?
• You didn’t tell Hathaway that you never actually went inside that wreck, though?
• And you knew that’s what Hathaway was really asking?
• Now you state that Hathaway never asked about medical information, correct?
• Ms. Allen, to be clear, at the time of this videoconference, you were aware of Lee’s hypertension?
• You also knew that individuals are advised not to scuba dive with high blood pressure?
• And you also knew that neither you nor Lee had ever dove below 80 feet?
• You did not volunteer any of this information to Hayden Hathaway?
• Now the Hepburn expedition began on July 2^nd, yes?
• You stated that Rodgers and Hathaway didn’t provide a lot of instruction once in the water, right?
• It was almost like they assumed you had more experience than you did, correct?
• Now you were Lee’s dive buddy for the dives before July 7^th, yes?
• So you were close to him the entire duration of these dives?
• In fact, no one was closer to Lee than you were?
• During the dive on July 6^th, you noticed Lee clutching his chest, correct?
• You suspected that Lee could be experiencing batotrauma or nitrogen narcosis?
• Ms. Allen, you didn’t report this information to any Neptune employee, right?
• You were worried about Lee’s ability to manage his oxygen level?
• But you never reported this information to Neptune or Rodgers?
• Now after the July 6^th dive, you confronted Lee about his struggles?
• Lee got upset about this, yes?
• So you dropped the subject?
• And you certainly didn’t tell anyone from Neptune?
• Ms. Allen, I want to discuss Lee’s dive log. You are familiar with this document?
• You saw Lee’s dive log before the dive on July 7^th, yes?
• Ms. Allen, Lee described the July 6^th dive as “feeling dead”, yes?
• Now the evening of July 6^th, you got sick?
• And you didn’t want Lee to dive without you, right?
• On the morning of July 7^th, you told Hathaway that Lee shouldn’t dive without you?
• Lee didn’t agree with you, right?
• Lee went into ‘lion mode’ at this point?
• At this point, Hathaway and Rodgers decided that Rodgers would act as Lee’s buddy?
• Ms. Allen, at this point, you still did not tell Hathaway or Rodgers about Lee’s struggles?
• You also didn’t mention seeing him clutch his chest?
• And you didn’t tell them that Lee “felt dead” after the July 6^th dive?
• After the divers entered the water, a storm came in around 10:15 AM, yes?
• The weather looked perfect for diving until 10 minutes before the storm arrived, yes?
• Ms. Allen, just to be clear about one last thing: you want to destroy Neptune and everyone who has ever worked for Neptune?