SEC Company Response from PENNICHUCK CORP (CIK 0000788885) — Jun 24, 2005
PENNICHUCK CORP (CIK 0000788885)
Date: June 24, 2005 · CIK: 0000788885 · Accession: 0001193125-05-130551
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File numbers found in text: 333-123725
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CORRESP
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ACCELERATION REQUEST
Pennichuck Corporation
25 Manchester Street
Merrimack, NH 03054
June 24, 2005
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Scott Anderegg
Re:
Pennichuck Corporation
Registration Statement on Form S-2
File No. 333-123725
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Regulations under the Securities Act of
1933, as amended, Pennichuck Corporation hereby requests that the effectiveness of its Registration Statement on Form S-2, File No. 333-123725, be accelerated so that such Registration Statement will become effective at 3:00 p.m. on June 28, 2005,
or as soon as possible thereafter.
Pennichuck Corporation
hereby acknowledges that Pennichuck is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff; staff comments or changes to 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 filings; and Pennichuck may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
Very truly yours,
PENNICHUCK CORPORATION
/s/ Donald L. Correll
Donald L. Correll
President, Chief Executive Officer and Director
[LETTERHEAD OF JANNEY MONTGOMERY SCOTT LLC]
June 24, 2005
Securities
and Exchange Commission
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington,
DC 20549
Attn.: Scott Anderegg
Re:
Pennichuck Corporation
Registration Statement on Form S-2
File No. 333-123725
Ladies and Gentlemen:
In connection with the above referenced Registration Statement, and pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Act”) the undersigned, as the representative of the underwriters, hereby joins in the request of Pennichuck Corporation that the effective date of such Registration Statement
(File No. 333-123725) be accelerated so that it becomes effective at 3:00 p.m., Eastern Time, on June 28, 2005 or as soon thereafter as practicable.
With respect to Rule 15c2-8 (the “Rule”) under the Securities Exchange Act of 1934, as amended, we wish to advise the Commission that Janney
Montgomery Scott LLC and Edward D. Jones & Co., L.P. have distributed or will distribute copies of the Preliminary Prospectus dated June 17, 2005 to any person who is expected to receive a confirmation of sale at least 48 hours prior to the date
we expect to mail such confirmations. Selected dealers, if any, represent that they will comply with the Rule.
The following provides information with respect to the distribution of Preliminary Prospectuses dated June 17, 2005 and to be distributed between June 21,
2005 and the requested effective time of the Registration Statement:
Securities and Exchange Commission
June 24, 2005
Page 2
Preliminary Prospectuses
Number of Copies
To Prospective Underwriters
500
To Individuals/Institutions
1222
To statistical and public services
5
Total
1727
Very truly yours,
JANNEY MONTGOMERY SCOTT LLC
By:
/s/ Joseph D. Culley, Jr.