SEC Company Response from EMERITUS CORP\WA\ (CIK 0001001604) — Aug 10, 2005

EMERITUS CORP\WA\ (CIK 0001001604)
Date: Aug. 10, 2005 · CIK: 0001001604 · Accession: 0001001604-05-000261

View on Edgar

AI Filing Summary & Sentiment

Date

December 31, 2004

Author

/s/

Form

CORRESP

Company

EMERITUS CORP\WA\ (CIK 0001001604)

Letter

Via EDGAR Division of Corporation Finance United States Securities and Exchange Commission Form 10-K for the fiscal year ended December 31, 2004 Filed March 31, 2005 Form l0-Q for the quarterly period ended March 31, 2005 Filed May 13, 2005

Dear Mr. Spirgel:

This letter is in response to your letter to us dated August 9, 2005, regarding the above mentioned filings. In the interest of keeping matters clear, organized, and in keeping with our understanding of your instructions, we repeated your comment in the same form it occurred in your letter to us. Immediately after your comment, we follow with our response.

Form l0-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)."

Answer: We understand the comment above and plan to use the corrected description in all future filings.

Sincerely,
/s/
Raymond R. Brandstrom

Show Raw Text

CORRESP
1
filename1.htm

      Second Response Letter

    August
      10, 2005

    Via
      EDGAR

    Mr.
      Larry
      Spirgel

    Assistant
      Director

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    Mail
      Stop
      3561

    Washington,
      DC 20549

    RE:

    Emeritus
      Corporation

    Form
      10-K
      for the fiscal year ended December 31, 2004

    Filed
      March 31, 2005

    Form
      l0-Q
      for the quarterly period ended March 31, 2005

    Filed
      May
      13, 2005

    Dear
      Mr.
      Spirgel:

    This
      letter is in response to your letter to us dated August 9, 2005, regarding
      the
      above mentioned filings. In the interest of keeping matters clear, organized,
      and in keeping with our understanding of your instructions, we repeated your
      comment in the same form it occurred in your letter to us. Immediately after
      your comment, we follow with our response.

    Form
      l0-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)."

        Answer:
          We
          understand the comment above and plan to use the corrected description
          in all
          future filings.

    Sincerely,

    /s/
      Raymond R. Brandstrom

    Raymond
      R. Brandstrom

    Vice
      President of Finance,

    Chief
      Financial Officer, and Secretary

SecProbe.io