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2457 Care Drive Tallahassee, Florida 32308 (850) 878-2411 - Telephone (850) 878-1230 – Facsimile e-mail:tall@idhlaw.com | 500 N. Westshore Blvd, Suite 1010 Tampa, Florida 33609 (813) 289-1020 - Telephone (813) 289-1070 - Facsimile e-mail:tampa@idhlaw.com |
REPLY TO TALLAHASSEE OFFICE
February 25, 2005
Christian Windsor, Esq. Special Counsel Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 | VIA FEDERAL EXPRESS |
| RE: | Partners Financial Corporation Form SB-2; Filed October 29, 2004; |
Amended December 9, 2004 and January 7, 2005; File No. 333-120068
Dear Mr. Windsor:
Enclosed, please find clean and marked copies of Pre-effective Amendment Number Three to Partners Financial Corporation’s Registration Statement on Form SB-2. Also enclosed is a copy of our transmittal letter of the same documents to the Office of Thrift Supervision (“OTS”). Although we still have objections to the OTS’ extra-jurisdictional involvement in this process, we believe we have presented a compromise that should satisfy it.
After you have had a chance to review the enclosures, please do not hesitate to call me or George Igler at (850) 878-2411 with any questions or comments.
Sincerely, |
| IGLER & DOUGHERTY, P.A. |
/s/Richard Pearlman |
Richard Pearlman |
| cc: | Jessica Livingston, Esq.,Securities and Exchange Commission |
Mr. Sharon M. Johnson,Securities and Exchange Commission
Mr. Don Walker,Securities and Exchange Commission