SEC Company Response from CRESCENT REAL ESTATE EQUITIES LTD PARTNERSHIP (CIK 0001010958) — Sep 8, 2005
CRESCENT REAL ESTATE EQUITIES LTD PARTNERSHIP (CIK 0001010958)
Date: Sept. 8, 2005 · CIK: 0001010958 · Accession: 0000950134-05-017394
AI Filing Summary & Sentiment
File numbers found in text: 333-42293
Letter
2300 N Street, N.W.
Washington, D.C. 20037-1128
Tel 202.663.8000
Fax 202.663.8007
www.pillsburylaw.com
September 8, 2005
Sylvia M. Mahaffey
202.663.8027
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Linda Van Doorn
Senior Assistant Chief Accountant
Re:
Crescent Real Estate Equities Limited Partnership
Form 10-K (File No. 333-42293) for Year Ended December 31, 2004
Response to Staff Comments of August 26, 2005
Ladies and Gentlemen:
On behalf of Crescent Real Estate Equities Limited Partnership (the “Partnership”), we are submitting this letter in response to the comment contained in the Staff’s letter of August 26, 2005, regarding the Partnership’s Form 10-K for the year ended December 31, 2004.
In order to facilitate the Staff’s review of this letter, we have included the text of the Staff’s comment preceding the Partnership’s response.
Form 10-K
Management’s Discussion and Analysis
Funds from Operations, page 59
1.
We have read and considered your response to comment 3. When distributions have been or are expected to be in excess of cash flows from operating activities, the Company should identify the alternative source of the excess distributions. In future filings, this disclosure should be made both when discussing historical distributions as well as when the Company is discussing the expected source of future distributions. Advise us if you plan to expand your disclosures in future filings.
Division of Corporation Finance
September 8, 2005
Page 2
Please be advised that, in its future filings on Form 10-K and Form 10-Q, when the Partnership’s historical distributions have been in excess of its cash flows from operating activities, the Partnership will identify the alternative source or sources of the excess distributions. Further, please be advised that, in its future filings on Form 10-K and Form 10-Q, when the Partnership’s future distributions are expected to be in excess of its cash flows from operating activities, the Partnership will identify the anticipated alternative source or sources of the expected excess future distributions.
Thank you for your consideration of this response. If you have any questions relating to this letter, I can be reached by telephone at 202.663.8027, by facsimile at 202.663.8028 (or 202.663.8007), or by e-mail at sylvia.mahaffey@pillsburylaw.com.
Thank you very much for your prompt attention to this matter.
Sincerely,
/s/ Sylvia M. Mahaffey
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2300 N Street, N.W.
Washington, D.C. 20037-1128
Tel 202.663.8000
Fax 202.663.8007
www.pillsburylaw.com
September 8, 2005
Sylvia M. Mahaffey
202.663.8027
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Linda Van Doorn
Senior Assistant Chief Accountant
Re:
Crescent Real Estate Equities Limited Partnership
Form 10-K (File No. 333-42293) for Year Ended December 31, 2004
Response to Staff Comments of August 26, 2005
Ladies and Gentlemen:
On behalf of Crescent Real Estate Equities Limited Partnership (the “Partnership”), we are
submitting this letter in response to the comment contained in the Staff’s letter of August 26,
2005, regarding the Partnership’s Form 10-K for the year ended December 31, 2004.
In order to facilitate the Staff’s review of this letter, we have included the text of the
Staff’s comment preceding the Partnership’s response.
Form 10-K
Management’s Discussion and Analysis
Funds from Operations, page 59
1.
We have read and considered your response to comment 3. When distributions have been or are
expected to be in excess of cash flows from operating activities, the Company should identify
the alternative source of the excess distributions. In future filings, this disclosure should
be made both when discussing historical distributions as well as when the Company is
discussing the expected source of future distributions. Advise us if you plan to expand your
disclosures in future filings.
Division of Corporation Finance
September 8, 2005
Page 2
Please be advised that, in its future filings on Form 10-K and Form 10-Q, when the
Partnership’s historical distributions have been in excess of its cash flows from operating
activities, the Partnership will identify the alternative source or sources of the excess
distributions. Further, please be advised that, in its future filings on Form 10-K and Form
10-Q, when the Partnership’s future distributions are expected to be in excess of its cash
flows from operating activities, the Partnership will identify the anticipated alternative
source or sources of the expected excess future distributions.
Thank you for your consideration of this response. If you have any questions relating to this
letter, I can be reached by telephone at 202.663.8027, by facsimile at 202.663.8028 (or
202.663.8007), or by e-mail at sylvia.mahaffey@pillsburylaw.com.
Thank you very much for your prompt attention to this matter.
Sincerely,
/s/ Sylvia M. Mahaffey
Sylvia M. Mahaffey
cc:
Yolanda Crittendon, Staff Accountant
Jerry R. Crenshaw, Managing Director and Chief Financial Officer
Suzanne Stevens, Senior Vice President and Controller