Quincy Montgomery Direct
Main points are in bold.
Quincy Montgomery Direct Examination
Q: Name and Occupation
Q: Education
Q: Qualifications and Relevant Publications
A: …I am a medical expert as well as a recreational scuba diver.
Q: Why are you here today?
A: I am here to offer my professional opinion as to the cause of Lee Allen’s death and to assess whether Neptune acted with due care and in accordance with industry standards.
Q: Are you being paid for your services today?
A: Of course. I have to cover my expenses, and my time is not free.
Q: What opinion do you wish to offer?
A: I have reached several conclusions that indicate that Neptune was not at fault in the accident of July 7, 2011.
Q: Okay, let’s back up a bit. Could you tell us a bit about your methods in reaching your conclusions?
A: I compared the facts of this case to what is known in the world of scuba diving medicine. I relied primarily on sections 9 through 14 of Scuba Diving 101, of which I can agree and confirm, and Breathing Gas Calculations. Breathing Gas Calculations is 100% accurate and is an accepted treatise in the field of scuba diving medicine. I also reviewed two affidavits—those of Allen and Rogers—as well as the medical record of Lee Allen, his diving log, and the Hepburn Expedition brochure.
Q: Did you pursue any additional information? (Can be rephrased if leading)
A: No. All of my information was secondhand, and this is not unusual for a consultant. All of my methods followed established, reliable, verified industry practices. I had sufficient facts to come to all my conclusions.
Main Point: Although no physical evidence or interviews were used, Montgomery is certain that he had sufficient facts to come to his conclusions
Q: Can you please tell us about those conclusions?
A: Well, first, I found that Lee Allen’s actions on July 7 contributed to his own death; this is because of a medical condition that was known to the Allens but not to Neptune.
Q: What do you mean by medical condition?
A: Lee Allen suffered from improving, but still significant, Stage II hypertension, or high blood pressure. He was aware of this diagnosis and its implications on scuba diving.
Q: What kind of implications?
A: Scuba divers with hypertension are at much greater risk for nitrogen narcosis, barotrauma, and pulmonary edema. Doctors Thomas Morrell and Benoit Cull and the Modern S. Lang facility have researched these effects, and these findings have been confirmed by numerous professional studies. It is universally accepted that a scuba diver with any degree of hypertension should not be in the water.
Q: How do these facts relate to Lee Allen?
A: Lee Allen was aware that he was suffering from hypertension, and chose to dive at the depths of the Neptune dive. The symptoms Reggie Rogers observed Lee Allen exhibit were consistent with somebody diving with hypertension; he consumed extra oxygen, and was at a greatly increased risk for nitrogen narcosis, at a more rapid onset than other divers.
Q: So how could this have affected the events of July 7, 2011?
A: Well, Lee Allen had completed several successful dives prior to that one. However, Lee Allen chose to withhold the information about the hypertension from Neptune. I believe that Lee Allen’s conduct caused or contributed to his death because it was his responsibility to manage his symptoms.
Q: What do you mean?
Main Point: Like I said, Reggie Rogers observed Lee Allen exhibiting symptoms consistent with Nitrogen Narcosis at 10:09am. It was the responsibility of Lee Allen, not Rogers, to recognize his symptoms, especially given his knowledge of his own increased propensity to Nitrogen Narcosis. When he felt those symptoms, he had both an obligation to monitor his oxygen consumption, and to ascend until the narcosis dissipated. There is no evidence that Allen fulfilled either obligation.
Q: Are there any further conclusions that you reached?
A: Well, another reason for why I feel that Neptune was not at fault is because I found that Rogers made the correct decision to surface without Allen.
Q: What do you mean?
A: I reviewed the oxygen consumption of Lee Allen and Reggie Rogers. I made sure to account for Rogers’ experience by assuming that he would use 10% less oxygen than an average diver. Even so, had Rogers not ascended when he did, he would have run out of oxygen himself. It is actually a bit of a miracle that he made it.
Q: Why was it a miracle?
Main Point: Like I said, it was Lee Allen’s responsibility to monitor his own oxygen levels, and he failed to. But for Rogers specifically, my calculations actually show that he wouldn’t have had enough oxygen to surface at all given the assumed sequence of events. However, this is a minute detail, as many factors come into play, including compression of oxygen, and I am still fully confident in my conclusion that Reggie Rogers had no choice but to ascend when he did.
