SEC Comment Letter for EMERITUS CORP\WA\ (CIK 0001001604) — Aug 9, 2005
EMERITUS CORP\WA\ (CIK 0001001604)
Date: Aug. 9, 2005 · CIK: 0001001604 · Accession: 0000000000-05-040968
AI Filing Summary & Sentiment
Referenced dates: June 13, 2005, May 27, 2005
Letter
August 9, 2005 Mr. Raymond R Brandstrom Vice President of Finance, Chief Financial Officer, and Secretary Emeritus Corporation 3131 Elliott Avenue Suite 500 Seattle, WA 98121 Form 10-Q for the quarterly period ended March 31, 2005 Filed May 13, 2005
Re: Emeritus Corporation Form 10-K for the fiscal year ended December 31, 2004 Filed March 31, 2005
Dear Mr. Brandstrom:
We have reviewed your supplemental response letter dated June 13, 2005 as well as your filing and have the following comments. As noted in our comment letter dated May 27, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 10-K for the fiscal year ended December 31, 2004
Consolidated Statement of Operations, page F-4
1. We note your response to prior comment 7. Notwithstanding your response, please revise the line item "Community Operations" to "Community Operations (exclusive of depreciation and amortization and facility lease expense shown separately below)."
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR. You may contact Michael Henderson, Staff Accountant, at (202) 551-3364 or Dean Suehiro, Senior Staff Accountant, at (202) 551-3384 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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<TYPE>LETTER
<SEQUENCE>1
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<TEXT>
Mail Stop 3561
August 9, 2005
Mr. Raymond R Brandstrom
Vice President of Finance, Chief Financial Officer, and Secretary
Emeritus Corporation
3131 Elliott Avenue
Suite 500
Seattle, WA 98121
Re: Emeritus Corporation
Form 10-K for the fiscal year ended December 31, 2004
Filed March 31, 2005
Form 10-Q for the quarterly period ended March 31, 2005
Filed May 13, 2005
Dear Mr. Brandstrom:
We have reviewed your supplemental response letter dated
June
13, 2005 as well as your filing and have the following comments.
As
noted in our comment letter dated May 27, 2005, we have limited
our
review to your financial statements and related disclosures and do
not intend to expand our review to other portions of your
documents.
Form 10-K for the fiscal year ended December 31, 2004
Consolidated Statement of Operations, page F-4
1. We note your response to prior comment 7. Notwithstanding your
response, please revise the line item "Community Operations" to
"Community Operations (exclusive of depreciation and amortization
and
facility lease expense shown separately below)."
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please file
your
response on EDGAR. You may contact Michael Henderson, Staff
Accountant, at (202) 551-3364 or Dean Suehiro, Senior Staff
Accountant, at (202) 551-3384 if you have questions regarding
comments on the financial statements and related matters. Please
contact me at (202) 551-3810 if you have any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Raymond R Brandstrom
Emeritus Corporation
August 9, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
</TEXT>
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