SEC Comment Letter for EASTERN SERVICES HOLDINGS, INC. (CIK 0001335795) — Oct 11, 2005
EASTERN SERVICES HOLDINGS, INC. (CIK 0001335795)
Date: Oct. 11, 2005 · CIK: 0001335795 · Accession: 0000000000-05-052077
AI Filing Summary & Sentiment
File numbers found in text: 333-128415
Letter
Mail Stop 4561 October 11, 2005 Akhee Rahman President and Chief Executive Officer Eastern Services Holdings, Inc. 269 S. Beverly Drive, #732 Beverly Hills, CA 90212-3851
Re: Eastern Services Holdings, Inc. Registration Statement on Form SB-2 Filed on September 19, 2005 File No. 333-128415
Dear Mr. Rahman:
This is to advise you that a preliminary review of the above registration statement indicates that it fails to comply with the requirements of the Securities Act of 1933, the rules and regulations under that Act, and the requirements of the form. For this reason, we will not perform a detailed examination of your registration statement, and we will not issue any comments because to do so would delay the review of other disclosure documents that do not contain comparable deficiencies. We have noted the following deficiencies, among other matters.
FORM SB-2
General 1. The notes to your financial statements and other portions of the document refer to a completely separate company, Grant Enterprises. Revise your disclosure concerning all events that are necessary to provide adequate information about the financial condition of your company and the risks of the common stock ownership to investors. As we expect your notes to the financial statements and disclosure in other related parts of your document to materially change, we expect to have substantial further comments when you file an amended document. 2. We note your address as listed on the front cover of the registration statement, and elsewhere in the prospectus, does not match the business address you provided on EDGAR. Please revise to provide consistent disclosure regarding your business address and phone number.
PART II
Signatures 3. Revise your signature page to identify your controller or principal accounting officer or indicate which signatories are performing similar functions. See the instructions for signatures contained in Form SB-2.
Exhibit 5.1 - Legality Opinion 4. We note that this opinion relates to the issuance of shares by Grant Enterprises, Inc. Please have counsel revise to opine on the offering in this registration statement.
* * * * *
You are advised that we will not recommend acceleration of the effective date of the registration statement and that, should the registration statement become effective in its present form, we would be required to consider what recommendation, if any, we should make to the Commission.
We suggest that you consider submitting a substantive amendment to correct the deficiencies or a request for withdrawal of the filing
If you have any questions regarding accounting issues, please call Jason Niethamer at (202) 551-3855. If you have any other questions, please call Rebekah Toton at (202) 551-3857. If you need further assistance, you may contact me at (202) 551-3735.
Sincerely,
Barbara C. Jacobs
Assistant Director
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Mail Stop 4561
October 11, 2005
Akhee Rahman
President and Chief Executive Officer
Eastern Services Holdings, Inc.
269 S. Beverly Drive, #732
Beverly Hills, CA 90212-3851
Re: Eastern Services Holdings, Inc.
Registration Statement on Form SB-2
Filed on September 19, 2005
File No. 333-128415
Dear Mr. Rahman:
This is to advise you that a preliminary review of the above
registration statement indicates that it fails to comply with the
requirements of the Securities Act of 1933, the rules and
regulations
under that Act, and the requirements of the form. For this
reason,
we will not perform a detailed examination of your registration
statement, and we will not issue any comments because to do so
would
delay the review of other disclosure documents that do not contain
comparable deficiencies. We have noted the following
deficiencies,
among other matters.
FORM SB-2
General
1. The notes to your financial statements and other portions of
the
document refer to a completely separate company, Grant
Enterprises.
Revise your disclosure concerning all events that are necessary to
provide adequate information about the financial condition of your
company and the risks of the common stock ownership to investors.
As
we expect your notes to the financial statements and disclosure in
other related parts of your document to materially change, we
expect
to have substantial further comments when you file an amended
document.
2. We note your address as listed on the front cover of the
registration statement, and elsewhere in the prospectus, does not
match the business address you provided on EDGAR. Please revise
to
provide consistent disclosure regarding your business address and
phone number.
PART II
Signatures
3. Revise your signature page to identify your controller or
principal accounting officer or indicate which signatories are
performing similar functions. See the instructions for signatures
contained in Form SB-2.
Exhibit 5.1 - Legality Opinion
4. We note that this opinion relates to the issuance of shares by
Grant Enterprises, Inc. Please have counsel revise to opine on
the
offering in this registration statement.
* * * * *
You are advised that we will not recommend acceleration of
the
effective date of the registration statement and that, should the
registration statement become effective in its present form, we
would
be required to consider what recommendation, if any, we should
make
to the Commission.
We suggest that you consider submitting a substantive
amendment
to correct the deficiencies or a request for withdrawal of the
filing
If you have any questions regarding accounting issues, please
call Jason Niethamer at (202) 551-3855. If you have any other
questions, please call Rebekah Toton at (202) 551-3857. If you
need
further assistance, you may contact me at (202) 551-3735.
Sincerely,
Barbara C. Jacobs
Assistant Director
cc: Via Facsimile (732) 577-1188
Gregg E. Jaclin, Esq.
Anslow & Jaclin, LLP
Telephone: (732) 409-1212
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Akhee Rahman
Eastern Services Holdings, Inc.
October 11, 2005
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