SEC Company Response from FAST EDDIE RACING STABLES INC (CIK 0000770461) — Mar 11, 2005
FAST EDDIE RACING STABLES INC (CIK 0000770461)
Date: March 11, 2005 · CIK: 0000770461 · Accession: 0001165527-05-000053
AI Filing Summary & Sentiment
Referenced dates: March 2, 2005
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Law Offices
Steven L. Siskind
645 Fifth Avenue - Suite 403
New York, NY 10022
(212) 750-2002
Via Fax (202) 942-9638
March 7, 2005
Mr. Jeffrey B. Werbitt
Office of Mergers and Acquisitions
United States Securities and Exchange Commission
Washington, D.C. 20549-0303
Re: Fast Eddie Racing Stables, Inc.
Schedule 14f-1 filed on February 23, 2005
File No. 005-80568
Staff Comment Letter of March 2, 2005
Dear Mr. Werbitt,
I am counsel to Fast Eddie Racing Stables, Inc. (the "Registrant"). I am in
receipt of the comments set forth in the Staff's letter, dated March 2, 2005
(the "Letter"), to Glenn A. Little with respect to the Schedule 14f-1 filed on
February 23, 2005 by the Registrant. My responses are set forth below. Paragraph
numbers correspond to the paragraph numbers of the Letter.
1. I am supplementally advising the Staff that a shareholder vote by the
Registrant's shareholders is not required in this transaction under
Florida law. The parties to the merger, the consent of whose
shareholders is a condition to merger effectiveness, are FERS
Acquisition Corp., Delaware corporation that is a newly-formed
wholly-owned subsidiary of the Registrant, and Duncan Capital
Financial Group, Inc., a Delaware corporation that is a non-reporting
entity.
2, 3, 4: I note the Staff's comments with respect to future filings,
which will be addressed as required by applicable regulations.
As requested by the Staff, this shall confirm, on behalf of the Registrant, the
Registrant's acknowledgment that:
the Registrant is responsible for the adequacy and accuracy of the
disclosure in its filings;
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Securities and Exchange Commission
March 7, 2005
Page 2 of 2
Staff comments or changes in disclosure in response to Staff comments
in the filings reviewed by the Staff do not foreclose the Commission from
taking any action with respect to the filing; and
the Registrant may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the Federal
securities laws of the United States.
Please direct any questions to me at (212) 750-2002. My fax number is (212)
838-7982.
Very truly yours,
/s/ Steven L. Siskind
-----------------------------
SLS/as
cc: Mr. Glenn A. Little
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