Hayden Hathaway Plaintiff Only dive service that takes recreational dives under 130 feet Company has

s only been around since 2006 so safety record is questionable Did not ask for health records (though claims to have inquired about their health) Believed that because cave diving was similar to wreck diving experience would translate Only allowed them to dive on the Hepburn expedition because they were buddies Did not inform them about the dangers of the Hepburn expedition Was aware of prior deaths connected to diving to the Hepburn Observed Lee Allen struggling Only let Lee dive because he threatened to sue Paired diver up with Dive master against regulation One reason he paired Lee with Reggie was to avoid refund Dives discontinued since accident Defense Neptune offers beginner to advanced dives/lessons Has experience with past Hepburn expeditions Neptune has never had a diver ask for a refund, due to minimizing risks Asked about health history and dive background Recommended that they complete two more dives deeper than 100 feet Told Lee he couldnt dive, and Lee got belligerent Checked weather prior to dive Unable to check weather in the morning due to internet troubles