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Date
Staff
Michael Verne
Response/Comments
Responded by phone 1/4/02. B. Michael Verne

Question

From: Michael Verne

To:

Subject: Re: 2 Filing Questions

1. Yes - Item 4(a) requires all documents that have been filed with the SEC by the person filing or any entity within it regardless of current status.

2. Yes. Also no data should be supplied for the current year for those entities.

(redacted) 1/4/02 1:24 PM

I have two small filing questions that I hope you can respond to.

1. One of our formerly public subsidiaries is now a private entity, do we have to file SEC documents?

2. I understand that the 1997 financial data is for all entities currently within the ultimate parent entity. If we are using year end 2000 numbers for the current year, do we have to remove data with respect to entities that have been sold since that year end data was compiled?

Thank you in advance for your attention to this matter.

(redacted)

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