EXCEL PROPERTIES, LTD.
17140 Bernardo Center Drive, #310
San Diego, CA 921278
(p) 858.613.1800 (f) 858.487.9890
March 30, 2005
Ms. Linda van Doorn
Mr. Josh Forgione
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: Excel Properties, Ltd.
Form 10-K for the year ended December 31, 2004
File No. 033-02320
Dear Ms. Linda van Doorn and Mr. Josh Forgione
Pursuant to your letter dated March 28, 2005, please note the following:
Staff Comment
Please have your auditors revise their report to indicate that their audits were conducted in accordance with standards of the Public Company Accounting Oversight Board (United States). Refer to the illustrative audit report in the Public Company Accounting Oversight Board’s Auditing Standard No. 1.
Company Response
The auditor report has been revised in accordance with the staff comment.
Also, per your letter, the company acknowledges that:
• The Company is responsible for the adequacy and accuracy of the disclosure in the filings:
• Staff comments or changes to disclosure in response to staff coments do not foreclose the Commission from taking any action with respect to the filings;
• 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.
Please feel free to call Gary Sabin at (858) 613-1800 ext. 410 or me at (858) 613-1800 ext. 445 with any questions.
Sincerely,
/s/ James Y. Nakagawa |
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James Y. Nakagawa |
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Cc: Gary Sabin, Excel Properties, Ltd.
Ray Bartholomew, Squire & Co.
Bruce Rushall, Esq., Rushall & McGeever