EXHIBIT 99

                          Pen-Tab Safe Harbor Statement
                          -----------------------------

     Information provided by the Company may contain certain forward-looking
information, which, as defined by the Private Securities Litigation Reform Act
of 1995 (the "Act"), may relate to such matters as sales, income, return on
equity, capital expenditures, dividends, capital structure, free cash flow, debt
to capitalization rations, internal growth rates, future economic performance,
management's plans and objectives for future operations or the assumptions
relating to any of the forward-looking information. This Safe Harbor Statement
is being made pursuant to the Act and with the intention of obtaining the
benefits of the so-called "safe harbor" provisions of the Act. The Company
cautions that forward-looking statements are not guarantees since there are
inherent difficulties in predicting future results, and that actual results
could differ materially from those expressed or implied in the forward-looking
statements. Factors that could cause actual results to differ include, but not
limited to, the following:

     Retail Economy. The Company's business depends on the strength of the
retail economies primarily in the U.S. and to a lesser extent in Canada by such
factors as consumer demand, the condition of the retail industry, currency
exchange rates and weather conditions. Recently, the retail industry has been
characterized by intense competition and consolidation.

     Nature of the Marketplace. The Company competes with numerous other
manufacturers and distributors, many of which are large and well-established. In
addition, the Company's principal customers are volume purchasers, many of which
are much larger than the Company and have significant bargaining power. The
combination of these market influences creates a very competitive marketplace,
resulting in difficulty in raising prices and the need to provide superior
services to the customers. These competitive pressures increase the risk of
losing substantial customers.

     Growth by Acquisition. The acquisition of companies is one of the
foundations of the Company's growth strategy. The Company's ability to make
strategic acquisitions at reasonable prices and to integrate the acquired
businesses within a reasonable period of time are important factors in the
Company's future earnings growth potential.