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his activities with Christine Enterprises and Thomas Daley, Mr.
Harrison panned for gold from 1985 to 1989 with Alex Saldivar.
Mr. Harrison did not recover any discernible amounts of gold from
his mining activities from 1985 to 1989.
During 1989, petitioners frequently visited Las Vegas,
Nevada. Mr. Harrison first became interested in treasure hunting
during one of his trips to Las Vegas in early 1989. Sometime
during the first quarter of 1989, Mr. Harrison met two gentlemen,
Patrick Payne and Hans Kruse, at the Hilton Hotel in Las Vegas,
Nevada. These individuals introduced Mr. Harrison to the idea of
searching for sunken Spanish galleons. Mr. Harrison had no
experience in treasure hunting prior to that time. Shortly after
this initial meeting in Las Vegas, as part of his investigation,
Mr. Harrison traveled to San Diego, California, to meet other
individuals associated with Patrick Payne. The other individuals
were Jerry James, Larry Haimson, and Glenn Tillman. Jerry James,
Patrick Payne, and Larry Haimson were associated with
International Recoveries, Inc. International Recoveries was
formed to seek treasures.
While in San Diego, petitioner also met with Glenn Tillman.
Glenn Tillman was the operation manager of the various survey
operations conducted by International Recoveries, though he was
not an owner of International Recoveries. Petitioner met with
several of the members of International Recoveries, as well as
Mr. Tillman, and did some investigation or independent research
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