1. Please state your name for the court

2. Mr. Connor, what occupational experience do you have?

3. Mr. Connor, how did you become involved in this case?

-During my duties as a Special Agent, I received a call from the The Man of the People, reporting a lost diver, and I began my investigation immediately.

4.What did your investigation entail?

-My entire investigation was performed on-site and it included witness interviews, my own inspection of “The Hepburn” and surrounding area, and an examination of physical evidence. I also interviewed a series of personnel.

5. Which individuals did you interview?

-I interviewed Hayden Hathaway, Andy Allen, and 4 other Neptune employees as well as 2 other divers.

6. During your interview with Hayden Hathaway, what did you discover?

-He stated that during “all of those dives, Lee Allen performed adequately, and that Lee Allen performed no better or worse than the other divers during the dives on July 4, 5, and 6” and that “before July 7, no one from Neptune had any concerns about Lee Allen's diving ability.”

21. What did Reggie Rodgers say during your interview with him?

-He stated that during “all of those dives, Lee Allen performed adequately, and that Lee Allen performed no better or worse than the other divers during the dives on July 4, 5, and 6” and that “before July 7, no one from Neptune had any concerns about Lee Allen's diving ability.”

22. Did you interview them together or separately?

-I interviewed them separately.

23. Did you indicate to Rodgers or Hathaway what the other said in the interview?

6. Other than interviews, what if anything did you base your conclusions on?

-I relied on current information accurately summarized in the 2006 article “Scuba Diving 101,” which I relied on in its entirety when forming opinions. I also took into account my experience as a special agent for the Coast Guard.

7. Were the methods and procedures you used standard in your field?

8. Let's talk about the Hepburn dive itself. What if any previous experience do you have with the Hepburn?

-In 2010 I received a call for a diver needing a recompression chamber because they were experiencing symptoms of nitrogen narcosis while at the The Hepburn.

9. What other experiences do you have with Neptune?

-405b: When a person's character or character trait is an essential element of a claim, the character or trait may also be proved by relevant specific instances of the person's conduct.

*if they try to use this to do safety stats, object, because its not specific*

9. Let's talk about the depth of the dive. How deep does Neptune take its divers on the Hepburn Expedition?

-Neptune takes its divers up to 190 ft.

11. How does 190 ft compare with recreational limits?

-The treatise SD101 indicates that recommended limits are 100 ft, and the absolute limit is 130 ft no matter the circumstances.

12. What are the depth limits based off of?

-They are based off of decades of research and are the consensus of all major scuba diving associations.

13. What added dangers are there at a depth of 170 to 190 ft?

-Nitrogen narcosis is exponentially worse; divers experience significantly slowed responses to stimuli, impaired judgment and reasoning, hallucinations, dizziness and confusion, and emotional reactions ranging from laughter to fear.

14. Now, what added dangers are there for diving in a wreck?

-Caves and wrecks pose unique dangers. A diver can easily become caught on lines or netting. A piece of the wreck can fall or dislodge, leaving the diver trapped. The lack of exposure to sunlight, as well as frequent appearance of silt, typically makes visibility poor or non-existent.

15. From a diver's perspective, what were the conditions in The Hepburn like?

-The wreck was very dark. I could not see more than 12 feet in any direction, even with a flashlight. I dove there during clear weather. At a depth of 170 feet, visibility extended about 10 feet inside the Hepburn, but during a severe storm, such as the one on July 7, those figures would likely be halved.

16. How did nitrogen narcosis affect your investigation in the Hepburn dive?

-My investigation was not impaired, because I did a full decompression in accordance with Table 5 in Scuba Diving 101. However, I did feel the onset of it. I learned through my many years of experience with diving how to minimize the effects of nitrogen narcosis.

17. What is your opinion on whether Neptune should lead a dive to the Hepburn?

-Neptune should not allow a dive to the Hepburn because of the dangers I mentioned.

18. Let's talk about the storm that day. Was there any indication that Neptune was aware of the weather?

-Casey French stated to me in his interview that two minutes before the group entered the water, French noticed storm clouds moving toward their location, yet neglected to say anything to Hathaway or anyone else.

19. What is your opinion on whether Neptune should have been diving, given what they knew about the weather?

-No, they should not. It is extremely dangerous to dive on the day of a known storm; a plethora of things could go wrong. They shouldn't have been diving to the Hepburn in the first place, but even more so with the storm, which could raise dust from the ocean bed, decrease visibility even more, and trap divers in an enclosed space.

24. As an expert investigator, what is your opinion on whether Neptune should have allowed Lee Allen to dive that day to the Hepburn?

-1) The dive itself is unsafe. 2) Neptune dove on the day of a storm. .

Neptune should not have led a dive to “The Hepburn” for two reasons. The Hepburn is unsafe for recreational divers under any circumstances due to its extreme depths, and wreck diving at those depths is even more dangerous. Secondly, the weather made the Hepburn wreck unusually dangerous, and Neptune should not have based the decision to dive on a prior day's forecast, particularly when the original forecast predicted a storm. These mistakes by Neptune directly resulted in Lee's separation from the group and impaired Neptune's ability to rescue Lee, leading ultimately to his death.