SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 4561
      July 11, 2005

Mr. Steve Bonenberger
President
Palomar Enterprises, Inc.
1802 N. Carson St. No. 212-2705
Carson City, NV 89701

	RE:	Palomar Enterprises, Inc.
		Form 8-K/A
		Filed July 8, 2005
            	File No. 0-32829

Dear Mr. Bonenberger:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      	Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 8-K/A filed July 8, 2005

1. Please revise the Form 8-K to include the two years of
information
required by Item 304(a)(1)(ii) of Regulation S-B.

2. In detail, describe the nature of each significant deficiency
and
the amounts involved, if any, regarding the significant
deficiencies
noted by your former accountants in their exhibit 16 letter.  Tell
us
in what period the reportable event and the steps you have

taken (or plan to take) and procedures you implemented (or plan to
implement) to correct each significant deficiency.  In addition,
please amend your 8K to include the significant deficiencies as
required by Item 304 (a)(1)(iv)(B) or tell us why no additional
disclosure is required.

3. Provide us with any letter or written communication to and from
the former accountants regarding any disagreements or reportable
events to management or the Audit Committee.

4. Please provide us with a schedule of your fiscal year end
fourth
quarter adjustments to close the books, or adjustments recorded in
connection with or as a result of the audit.  Clearly explain the
reason for each adjustment.  For each adjustment, show us the
impact
on pre-tax net loss.  Quantify the net effect of all adjustments
on
pre-tax net income (loss).  Also, tell us why none of the
adjustments
relate to prior period.  Explain in detail why you believe the
timing
of each adjustment is appropriate.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed investment decision.  Since the company and its
management are in possession of all facts relating to a company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	Please provide the supplemental information requested above
within five business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3469.

								Sincerely,

								Thomas Flinn
								Staff Accountant
Mr. Steve Bonenberger
Palomar Enterprises, Inc.
July 11, 2005
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