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SEC Company Response from RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183) — Apr 26, 2005

RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183)
Date: April 26, 2005 · CIK: 0000842183 · Accession: 0000950124-05-002700

AI Filing Summary & Sentiment

Referenced dates: April 18, 2005

Date
April 26, 2005
Author
/s/ Richard J. Smith
Form
CORRESP
Company
RAMCO GERSHENSON PROPERTIES TRUST (CIK 0000842183)

Letter

Via EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: Thomas Flinn Re: Ramco-Gershenson Properties Trust Form 8-K filed April 15, 2005 File No. 0-49838

Dear Mr. Flinn:

This letter is being sent to you by Ramco-Gershenson Properties Trust (the “Company”) in response to your letter dated April 18, 2005 regarding your comments on the above referenced Form 8-K. The Company is filing today via EDGAR this response letter and an amendment to the Form 8-K in response to your comments.

The Company has revised the Form 8-K to include additional information regarding the Company’s former independent registered public accounting firm, Deloitte & Touche LLP (“Deloitte & Touche”) having expressed an adverse opinion on the effectiveness of the Company’s internal controls over financial reporting because of a material weakness. The Company had not included such additional information in its initial Form 8-K filing because such event did not constitute a disagreement with Deloitte & Touche.

The amendment to Form 8-K being filed today by the Company includes as an exhibit a letter from Deloitte & Touche in response to the disclosures made by the Company in the amendment to Form 8-K.

As requested in your letter, the Company acknowledges that:

• The Company is responsible for the adequacy and accuracy of the disclosure in its filings with the Securities and Exchange Commission (the “Commission”);

• 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 filing; and

• The Company 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.

If you have any questions or comments regarding this letter or the amendment to Form 8-K being filed today, please contact me at (248) 592-6200.

Very truly yours,
/s/ Richard J. Smith

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CORRESP
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corresp

[Ramco-Gershenson Properties Trust letterhead]

April 26, 2005

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Thomas Flinn

         Re:
    Ramco-Gershenson Properties Trust

Form 8-K filed April 15, 2005

File No. 0-49838

Dear Mr. Flinn:

     This letter is being sent to you by Ramco-Gershenson Properties Trust (the “Company”) in
response to your letter dated April 18, 2005 regarding your comments on the above referenced Form
8-K. The Company is filing today via EDGAR this response letter and an amendment to the Form 8-K
in response to your comments.

     The Company has revised the Form 8-K to include additional information regarding the Company’s
former independent registered public accounting firm, Deloitte & Touche LLP (“Deloitte & Touche”)
having expressed an adverse opinion on the effectiveness of the Company’s internal controls over
financial reporting because of a material weakness. The Company had not included such additional
information in its initial Form 8-K filing because such event did not constitute a disagreement
with Deloitte & Touche.

     The amendment to Form 8-K being filed today by the Company includes as an exhibit a letter
from Deloitte & Touche in response to the disclosures made by the Company in the amendment to Form
8-K.

     As requested in your letter, the Company acknowledges that:

    •
    The Company is responsible for the adequacy and accuracy of the disclosure
in its filings with the Securities and Exchange Commission (the “Commission”);

    •
    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 filing; and

    •
    The Company 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.

     If you have any questions or comments regarding this letter or the amendment to Form 8-K being
filed today, please contact me at (248) 592-6200.

Very truly yours,

/s/ Richard J. Smith

Richard J. Smith

Chief Financial Officer