SEC Company Response from CENTURY PACIFIC FINANCIAL CORP (CIK 0000791770) — Dec 9, 2005
CENTURY PACIFIC FINANCIAL CORP (CIK 0000791770)
Date: Dec. 9, 2005 · CIK: 0000791770 · Accession: 0001170918-05-000935
AI Filing Summary & Sentiment
Letter
RE: CENTURY PACIFIC FINANCIAL CORPORATION RESPONSES TO STAFF COMMENTS OF DECEMBER 6, 2005 WITH RESPECT TO:
STUBBS, ALDERTON & MARKILES, LLP LETTERHEAD JOHN MCILVERY Partner Direct Voice 818.444.4502 Direct Fax 818.474.8602 E-Mail jmcilvery@biztechlaw.com
December 8, 2005
VIA EDGAR
Securities and Exchange Commission Division of Corporation Finance Mail Stop 3561 Washington, D.C. 20549
ITEM 4.01 FORM 8-K FILED DECEMBER 6, 2005 FILE NO. 0-16075
Ladies and Gentlemen:
On behalf of Century Pacific Financial Corporation (the "COMPANY"), we hereby provide the following responses in reply to the Staff's comment letter, dated December 6, 2005 (the "COMMENT LETTER"). In addition, we have enclosed for filing an amendment on Form 8-K/A (the "FORM 8-K/A"), which amends the Company's Current Report on Form 8-K filed on December 6, 2005
The factual information provided herein relating to the Company has been made available to us by the Company. Paragraph numbering used for each supplemental response set forth below corresponds to the numbering used in the Comment Letter.
FORM 8-K
1. PLEASE REVISE YOUR DISCLOSURE WITH RESPECT TO DISAGREEMENTS TO COVER THE SUBSEQUENT INTERIM PERIOD THROUGH THE DATE OF DISMISSAL. WE WOULD EXPECT YOU TO BE ABLE TO STATE THAT FOR THE TWO MOST RECENT FISCAL YEARS AND THE SUBSEQUENT INTERIM PERIOD THROUGH NOVEMBER 30, 2005, THERE WERE NO DISAGREEMENTS WITH SHELLEY INTERNATIONAL..., IF TRUE. PLEASE REVISE OR ADVISE.
The Company has revised the disclosure in the Form 8-K/A in response to the Staff's comments.
In addition to the foregoing, attached to this response letter is a letter from the Company stating the Company's acknowledgement of the matters requested on Page 2 of the Comment Letter.
15821 Ventura Boulevard, Suite 525, Encino, California 91436 office > 818.444.4500 fax > 818.444.4520 www.biztechlaw.com <PAGE> Securities and Exchange Commission December 8, 2005 Page 2
We hope the above is responsive to the Staff's comments. If you have any questions or require any additional information or documents, please telephone me at (818) 444-4502.
Sincerely,
/s/ John J. McIlvery ------------------------- John J. McIlvery
cc: Darryn Barber
<PAGE>
CENTURY PACIFIC FINANCIAL CORPORATION 150 WEST JEFFERSON BOULEVARD LOS ANGELES, CALIFORNIA 90007
December 8, 2005
Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Mail Stop 3561
RE: CENTURY PACIFIC FINANCIAL CORPORATION. RESPONSES TO STAFF COMMENTS OF DECEMBER 6, 2005 WITH RESPECT TO:
ITEM 4.01 FORM 8-K FILED DECEMBER 6, 2005 FILE NO. 0-16075
Ladies and Gentlemen:
This letter is provided by Century Pacific Financial Corporation (the "Company") in response to the comment letter from the Staff of the Securities Exchange Commission dated December 6, 2005 with respect the filing listed above. The Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
o staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
o the Company may not assert this action 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,
Century Pacific Financial Corporation
Show Raw Text
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STUBBS, ALDERTON & MARKILES, LLP
LETTERHEAD
JOHN MCILVERY
Partner
Direct Voice 818.444.4502
Direct Fax 818.474.8602
E-Mail jmcilvery@biztechlaw.com
December 8, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
Washington, D.C. 20549
RE: CENTURY PACIFIC FINANCIAL CORPORATION
RESPONSES TO STAFF COMMENTS OF DECEMBER 6, 2005 WITH RESPECT
TO:
ITEM 4.01 FORM 8-K FILED DECEMBER 6, 2005
FILE NO. 0-16075
Ladies and Gentlemen:
On behalf of Century Pacific Financial Corporation (the "COMPANY"), we
hereby provide the following responses in reply to the Staff's comment letter,
dated December 6, 2005 (the "COMMENT LETTER"). In addition, we have enclosed for
filing an amendment on Form 8-K/A (the "FORM 8-K/A"), which amends the Company's
Current Report on Form 8-K filed on December 6, 2005
The factual information provided herein relating to the Company has
been made available to us by the Company. Paragraph numbering used for each
supplemental response set forth below corresponds to the numbering used in the
Comment Letter.
FORM 8-K
1. PLEASE REVISE YOUR DISCLOSURE WITH RESPECT TO DISAGREEMENTS TO COVER
THE SUBSEQUENT INTERIM PERIOD THROUGH THE DATE OF DISMISSAL. WE WOULD
EXPECT YOU TO BE ABLE TO STATE THAT FOR THE TWO MOST RECENT FISCAL
YEARS AND THE SUBSEQUENT INTERIM PERIOD THROUGH NOVEMBER 30, 2005,
THERE WERE NO DISAGREEMENTS WITH SHELLEY INTERNATIONAL..., IF TRUE.
PLEASE REVISE OR ADVISE.
The Company has revised the disclosure in the Form 8-K/A in response to
the Staff's comments.
In addition to the foregoing, attached to this response letter is a
letter from the Company stating the Company's acknowledgement of the matters
requested on Page 2 of the Comment Letter.
15821 Ventura Boulevard, Suite 525, Encino, California 91436
office > 818.444.4500 fax > 818.444.4520 www.biztechlaw.com
<PAGE>
Securities and Exchange Commission
December 8, 2005
Page 2
We hope the above is responsive to the Staff's comments. If you have
any questions or require any additional information or documents, please
telephone me at (818) 444-4502.
Sincerely,
/s/ John J. McIlvery
-------------------------
John J. McIlvery
cc: Darryn Barber
<PAGE>
CENTURY PACIFIC FINANCIAL CORPORATION
150 WEST JEFFERSON BOULEVARD
LOS ANGELES, CALIFORNIA 90007
December 8, 2005
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Mail Stop 3561
RE: CENTURY PACIFIC FINANCIAL CORPORATION.
RESPONSES TO STAFF COMMENTS OF DECEMBER 6, 2005 WITH RESPECT
TO:
ITEM 4.01 FORM 8-K FILED DECEMBER 6, 2005
FILE NO. 0-16075
Ladies and Gentlemen:
This letter is provided by Century Pacific Financial Corporation (the
"Company") in response to the comment letter from the Staff of the Securities
Exchange Commission dated December 6, 2005 with respect the filing listed above.
The Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of
the disclosure in the filing;
o staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any
action with respect to the filing; and
o the Company may not assert this action 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,
Century Pacific Financial Corporation
By: /S/ DARRYN BARBER
-----------------------------
Darryn Barber
Chief Financial Officer
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