WASHINGTON, D.C. OFFICE Suite 800 1850 M Street, N.W. Washington, D.C. 20036 Telephone: (202) 263-4300 Facsimile: (202) 263-4329 | SMITH, GAMBRELL & RUSSELL,LLP ATTORNEYS AT LAW | FLORIDA OFFICE Suite 2200, Bank of America Tower 50 North Laura Street Jacksonville, GL 32202 Telephone: (904) 598-6100 Facsimile: (904) 598-6300 | ||
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M. Timothy Elder Direct Dial: 404-815-3532 Direct Fax: 404-685-6832 E-Mail: telder@sgrlaw.com | ||||
May 25, 2006
Jim B. Rosenberg, Esq.
Senior Assistant Chief Accountant
Securities and Exchange Commission
Judiciary Plaza
100 F Street, N.E.
Mail Stop 6010
Washington, D.C. 20549
| Re: | SunLink Health Systems, Inc. |
Form 10-K for Fiscal Year Ended June 30, 2005
Filed September 16, 2005
File No. 000-12607
Dear Mr. Rosenberg:
I am writing in furtherance to your letter dated May 1, 2006 with respect to your review of certain items in the Form 10-K of SunLink Health Systems, Inc. (the “Company”), for the fiscal year ended June 30, 2005, and our subsequent telephone calls with your office, including our conference call with Keira Ino of your office on May 24, 2006. As we have discussed with Ms. Ino, this letter confirms, on behalf the Company, that SunLink will respond with revised proposed disclosure language with respect to the Allowance for Doubtful Accounts disclosure, and, in such response, will likewise confirm that the Company will provide a reconciliation of its Adjusted EBITDA to the closest GAAP liquidity measure, as requested per your May 1, 2006 letter.
As discussed with Ms. Ino, the Company expects to provide further written responses by June 13, 2006. We appreciate the Staff’s accommodation on the timing of a further written response.
Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
May 25, 2006
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If the Staff has any questions concerning this response letter, please contact the undersigned at 404-815-3532 or my partner, Howard E. Turner, at 404-815-3594.
Very truly yours,
M. Timothy Elder
MTE:apm
| cc: | Robert M. Thornton |
Joseph T. Morris
Mark J. Stockslager
Howard E. Turner, Esq.
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