SecProbe.io

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Mail Stop 3561
								December 9, 2005

C. Michael Nurse
Siteworks Building and Development Co.
P.O. Box 331238
Miami, Florida 33133

Re:	Siteworks Building and Development Co.
	Item 4.02 Form 8-K
      Filed December 7, 2005
	File No. 001-32528

Dear Mr. Nurse:

      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 more
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K Item 4.02

	Revise to disclose the date you concluded that your financial
statement disclosure should no longer be relied on or the date you
were notified by your independent accountant that your financial
statement disclosure should no longer be relied on.

	Revise to disclose a brief description of the facts
underlying
your conclusion to remove Note 12 from your financial statement
disclosures.

	Revise to state whether the audit committee, or the board of
directors in the absence of an audit committee, or authorized
officer
or officers, discussed with the independent accountant the matters
disclosed in the filing;

	Item 4.02(c) of Form 8-K requires you to provide your
independent accountant with a copy of the disclosure you are
making
in response to Item 4.02(b) and request that it furnish you with a
letter stating whether it agrees with the statements you have made
in
response to Item 4.02(b).  If your independent accountant does not
agree with your disclosure, it should explain why not.  You should
amend your Form 8-K to file this letter as an exhibit no later
than
two business days after you receive it.

      We note that you intend to file restated financial
statements.
Please tell us how, and when, you will file them.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and 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.

	If you have any questions, please call Babette Cooper at
(202)
551-3396

							Sincerely,

							Babette Cooper
							Staff Accountant

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE

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