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of Maxfield's visit to PI in 1982. Maxfield explained the
transactions to Addington in his own words. The two also
discussed PI, the people organizing the Partnerships, and the
value of the machine. Maxfield explained to Addington that an
audit would focus on the value of the machine. Addington
understood that Wible had visited PI and that he was impressed by
the factory and the machines. Addington also recalled speaking
to Sann about the proposal. Although he was initially skeptical,
Addington felt "more positive" about the investment after
speaking with Maxfield and Sann.
Addington never met Roberts or knew anything about him. He
did not believe that the success of the Partnerships depended
upon Roberts' personal efforts. Addington did not know how the
Sentinel EPE recycler worked, in a technical sense, and he never
saw one or asked to see one. He did not personally investigate
the recyclers or the entities involved in the transactions.
Addington knew that Maxfield's expertise was in taxation, and he
had no reason to believe that Maxfield had a background in
plastics recycling or engineering. He recalled that Maxfield did
not press anyone to invest in the Plastics Recycling
transactions, and Addington never felt like he was being
subjected to a hard sell.
3. David M. Cohn
Petitioner David M. Cohn (Cohn) resided in New York, New
York, when his petitions were filed. Cohn earned an
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