SEC Company Response from GOLDEN EAGLE INTERNATIONAL INC (ADGO) (CIK 0000869531) — Jun 2, 2005
GOLDEN EAGLE INTERNATIONAL INC (ADGO) (CIK 0000869531)
Date: June 2, 2005 · CIK: 0000869531 · Accession: 0000869531-05-000033
AI Filing Summary & Sentiment
File numbers found in text: 000-23726
Referenced dates: March 1, 2005
Letter
Via Federal Express May 25, 2005 H. Roger Schwall, Assistant Director Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549-0405
Re: Golden Eagle International, Inc. Form 10-K filed April 15, 2005 File No. 000-23726
Dear Sir:
This letter is a supplement to our letter to you of May 19, 2005, sent on behalf of Golden Eagle International, Inc. ("GEII"). This letter contains additional information in response to your fourth question in which you asked :
4.
It is the staff’s position that prior to declaring reserves, the company should have obtained a “final” or “bankable”feasibility study and employed the historic three-year average price for the economic analysis. In addition, the company should have submitted all necessary permits and authorizations, including environmental, to governmental authorities.
Supplementally, provide the Cangalli Reserves report prepared by Carlos Thompson and Giovanni Viscarra, dated February 2004, as referenced on page 15 and the Buen Futuro Reserve Report prepared by Michael Biste, Ronald Atwood, and Hugo Aparacio, dated February 2004. Include production from these properties since publication and recent cutoff grade calculations. To minimize shipping and handling costs, this report may be sent on a CD-ROM.
The informatioin on the CD-ROM that GEII sent you with our May 19, 2005, letter included the reserve reports for both Cangalli and Buen Futuro. With this letter, we have included the 2005 confirmations, as follows:
o
Letter dated March 1, 2005, from Michael H. Biste, Ph.D., confirming “that the reserve estimates made in [his] report are at least as viable as they were when made in February 2004, and actually are considerably more viable.”
o
Letter dated March 1, 2005, from Giovanni Viscarra, Geologist,, confirming “that the reserve estimates made in [his] report are at least as viable as they were when made in February 2004, and actually are considerably more viable.”
o
Letter dated March 1, 2005, from Mr. Viscarra offering his opinion that GEII “does not have any environmental remediation obligation at the Cangalli gold mine.”
We have also included Dr. Biste’s and Mr. Viscarra’s representations to Gordon, Hughes & Banks, GEII’s independent registered public accountants. Please do not hesitate to let us know if you have any other questions or comments, or if you need further explanation of any of the answers.
Sincerely yours,
Herrick K. Lidstone, Jr.
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CORRESP
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filename1.htm
BURNS, FIGA & WILL,
P.C.
Via Federal Express
May 25, 2005
H. Roger Schwall,
Assistant Director
Division of Corporation Finance
Securities and Exchange
Commission
Washington, D.C. 20549-0405
Re:
Golden Eagle International, Inc.
Form 10-K filed April 15, 2005
File
No. 000-23726
Dear Sir:
This letter is a supplement to our
letter to you of May 19, 2005, sent on behalf of Golden Eagle International, Inc.
("GEII"). This letter contains additional information in response to your fourth
question in which you asked :
4.
It
is the staff’s position that prior to declaring reserves, the company
should have obtained a “final” or “bankable”feasibility
study and employed the historic three-year average price for the economic
analysis. In addition, the company should have submitted all necessary
permits and authorizations, including environmental, to governmental
authorities.
Supplementally,
provide the Cangalli Reserves report prepared by Carlos Thompson and Giovanni Viscarra,
dated February 2004, as referenced on page 15 and the Buen Futuro Reserve Report
prepared by Michael Biste, Ronald Atwood, and Hugo Aparacio, dated February 2004.
Include production from these properties since publication and recent cutoff grade calculations.
To minimize shipping and handling costs, this report may be sent on a CD-ROM.
The informatioin on the CD-ROM that
GEII sent you with our May 19, 2005, letter included the reserve reports for both Cangalli
and Buen Futuro. With this letter, we have included the 2005 confirmations, as follows:
o
Letter
dated March 1, 2005, from Michael H. Biste, Ph.D., confirming “that the reserve
estimates made in [his] report are at least as viable as they were when made in February
2004, and actually are considerably more viable.”
o
Letter
dated March 1, 2005, from Giovanni Viscarra, Geologist,, confirming “that the
reserve estimates made in [his] report are at least as viable as they were when made in
February 2004, and actually are considerably more viable.”
o
Letter
dated March 1, 2005, from Mr. Viscarra offering his opinion that GEII “does not have
any environmental remediation obligation at the Cangalli gold mine.”
We have also included Dr.
Biste’s and Mr. Viscarra’s representations to Gordon, Hughes & Banks,
GEII’s independent registered public accountants. Please do not hesitate to let us
know if you have any other questions or comments, or if you need further explanation of
any of the answers.
Sincerely yours,
Herrick K. Lidstone, Jr.
For the Firm
Cc: Golden Eagle
International, Inc.
Enclosures: As described