| Jonathan Harwell | John M. Brittingham | Barbara D. Holmes | Christopher A. Scharman | |||
| Lin S. Howard * | Susan V. Sidwell | Alix Coulter Cross | Tracy M. Lujan | |||
| Ernest E. Hyne II | John F. Blackwood | Kris Kemp | Jonathan Stanley | |||
| Craig V. Gabbert, Jr. | D. Alexander Fardon | J. Greg Griffen | Kenneth S. Byrd | |||
| Mark Manner | Michael R. Hill | Leslie B. Wilkinson, Jr. | W. Christopher Andrews | |||
| Glen Allen Civitts | Joseph Allen Kelly | Ryan D. Brown | ||||
| Glenn B. Rose | David Cox | David P. Cañas | ||||
| John N. Popham IV | Curtis Capeling | David Simcox | *Of Counsel |
January 9, 2008
VIA EDGAR & FACSIMILE
Mr. Larry Spirgel
Assistant Director
United States Securities and Exchange Commission
Division of Corporation Finance, Mail Stop 3720
450 Fifth Street, N.W.
Washington, D.C. 20549
Assistant Director
United States Securities and Exchange Commission
Division of Corporation Finance, Mail Stop 3720
450 Fifth Street, N.W.
Washington, D.C. 20549
| RE: | Advocat Inc. | |
| Form 10-K for the fiscal year ended December 31, 2006 | ||
| Filed March 14, 2007 | ||
| Form 10-Q for the quarterly period ended September 30, 2007 | ||
| File No. 001-12996 |
Dear Mr. Spirgel:
This is a written request for an extension of the time allowed for Advocat to respond to your letter dated December 28, 2007 regarding Advocat Inc.’s (the Company) filing referenced above. Mr. Riddle, the Company’s CFO and addressee of the letter was out of the office until Monday January 7, 2008. In addition Advocat is currently in the process of closing its books for the end of the fiscal year. Therefore, we respectfully request that you allow Advocat to file its response to your letter on or before January 31, 2008. I spoke to Kathryn Jacobson yesterday, and she indicated that there was not a problem with this request provided we filed a written request by EDGAR.
Advocat is committed to fully complying with the SEC disclosure requirements. We would like a little more time to ensure that we can adequately respond to each item in your comment letter. If you have any problems or concerns with receiving our response on or before January 31, 2008, please call me at (615) 251-1083 to discuss.
| Sincerely, HARWELL HOWARD HYNE GABBERT & MANNER, P.C. | ||||
| /s/ Susan Sidwell | ||||
| Susan V. Sidwell | ||||
SVS/led
cc: Kathryn Jacobson
cc: Kathryn Jacobson
Kyle Moffatt
315Deaderick Street, Suite 1800 Nashville, Tennessee 37238-1800
phone 615-256-0500 fax 615-251-1059 www.h3gm.com
phone 615-256-0500 fax 615-251-1059 www.h3gm.com