June 2, 2009
Mail Stop 3561
Mr. John Reynolds
Assistant Director | Filed via EDGAR |
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Form 10-K for fiscal year ended December 31, 2008
Filed March 6, 2009
File No. 001-09848
Dear Mr. Reynolds:
Almost Family, Inc. appreciates the opportunity to respond to the comment provided by the Commission staff contained in your correspondence dated May 19, 2009 for the corporation and filing listed above.
Exhibits, page 67
SEC Comment #1:
| • | Please file the omitted schedules from Exhibit 10.17 or advise us why they are not material. We note that you may be able to file the omitted schedules under a confidential treatment request under Rule 24b-4 of the Exchange Act of 1934. |
Management’s Response to Comment #1:
In response to your Comment #1, we will re-file the credit agreement (previously filed as the Form 10-K Exhibit 10.17) as an exhibit to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2009. As re-filed, the credit agreement will include all schedules.
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In responding to this comment, the Company hereby acknowledges:
| • | 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 comments do not foreclose the Commission from taking any action with respect to the filings; and |
Mr. John Reynolds
June 2, 2009
Page 2
| • | 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. |
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Please contact me at (502) 891-1042 or our legal counsel, James A. Giesel, at (502) 568-0307, if you have any questions.
Sincerely,
/s/ C. Steven Guenthner
C. Steven Guenthner
Senior Vice President and
Chief Financial Officer