July 7, 2005 Via Facsimile (925) 871-4046 and U.S. Mail Chip Patterson Vice President and General Counsel MacKenzie Patterson Fuller, Inc. 1640 School Street Moraga, CA 94556 RE:	Concord Milestone Plus, LP Amended Schedule TO-T filed June 24, 2005 by Sutter Opportunity Fund 3, LLC, 	Sutter Opportunity Fund 3 (TE), LLC, SCM Special Fund, LLC, MacKenzie Patterson Fuller, Inc., Robert E. Dixon, and C.E. Patterson File No. 005-40562 Ladies and Gentlemen: 	We note your response to each of our prior comments regarding Mr. Patterson`s inclusion in the Schedule TO-T as a bidder but his absence from the Offer to Purchase as a purchaser. We do not agree with the analysis and conclusion set forth in your response letters. We have reviewed the arguments in support of your position that Mr. Patterson may be a bidder in the Schedule TO-T while not being a purchaser in the Offer to Purchase. Because Mr. Patterson is a bidder in the tender offer, he is also deemed to be a purchaser, and should appear as such, in the Offer to Purchase. While the staff of the Division of Corporation Finance will not undertake any further review of the Schedule TO-T at this time, the staff comments described above remain outstanding. Please direct any questions to me at (202) 551-3619. You may also contact me via facsimile at (202) 772-9203. 								Sincerely, 								Daniel F. Duchovny 								Attorney-Advisor 								Office of Mergers & Acquisitions ?? ?? ?? ?? UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE