TABLE OF CONTENTS


PART I.

- --------------------------------------------------------------------------------

FINANCIAL INFORMATION
Item 1.          Financial Statements
Item 2.          Management's Discussion and Analysis of Financial Condition and
Item 3.          Quantitative and Qualitative Disclosures About Market Risk
Item 4.          Controls and Procedures

PART II.

- --------------------------------------------------------------------------------

OTHER INFORMATION

Item 6.          Exhibits and Reports on Form 8-K

SIGNATURES
EXHIBIT INDEX


EX 10.16

EX 10.17

EX-31.1

EX-31.2

EX-32




                                    FORM 10-Q
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549


[ X ]    QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
         EXCHANGE ACT OF 1934.

                For the quarterly period ended October 30, 2004.

                                       OR

[   ]    TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
         EXCHANGE ACT OF 1934.

For the transition period from                 to                .
                               ---------------    ---------------


                        Commission file number 001-14565


                                  FRED'S, INC.
             (Exact name of registrant as specified in its charter)


              Tennessee                            62-0634010
    (State or other jurisdiction of             (I.R.S. Employer
    incorporation or organization)              Identification No.)

4300 New Getwell Rd., Memphis, Tennessee              38118
(Address of principal executive offices)            (zip code)

                                 (901) 365-8880
              (Registrant's telephone number, including area code)

Indicate by check mark whether the registrant (1) has filed all reports required
to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during
the  preceding 12 months (or for such  shorter  period that the  registrant  was
required  to file  such  reports),  and  (2) has  been  subject  to such  filing
requirements for the past 90 days.
Yes      X     .  No            .
    -----------      -----------

Indicate by check mark whether the registrant is an accelerated filer.
Yes      X        No
    -----------      -----------

The  registrant  had  39,384,148  shares of Class A voting,  no par value common
stock outstanding as of December 3, 2004.

                                       1


                                  FRED'S, INC.

                                      INDEX

                                                                        Page No.
- --------------------------------------------------------------------------------

Part I - Financial Information

  Item 1 - Financial Statements (unaudited):

    Condensed Consolidated Balance Sheets as of
     October 30, 2004 and January 31, 2004                                     3

    Condensed Consolidated Statements of Income
     for the Thirteen Weeks Ended October 30, 2004
     and November 1, 2003 and the Thirty-nine Weeks
     Ended October 30, 2004 and November 1, 2003                               4

    Condensed Consolidated Statements of Cash Flows
     for the Thirty-nine Weeks Ended October 30, 2004
     and November 1, 2003                                                      5

    Notes to Condensed Consolidated Financial Statements                   6 - 7

  Item 2 - Management's Discussion and
             Analysis of Financial Condition and
             Results of Operations                                        8 - 12

  Item 3 - Quantitative and Qualitative Disclosure
             about Market Risk                                                12

  Item 4 - Controls and Procedures                                       12 - 13

Part II - Other Information                                                   14
- ---------------------------
       Item 6 - Exhibits and Reports on Form 8-K

Signatures                                                                    15
- ----------
         Exhibit - 31.1
         Exhibit - 31.2
         Exhibit - 32


                                       2



                                  FRED'S, INC.
                      CONDENSED CONSOLIDATED BALANCE SHEETS

                   (in thousands, except for number of shares)

                                                                                                  
                                                                               October 30,              January 31,
                                                                                    2004                    2004
                                                                                    ----                    ----
ASSETS:                                                                        (unaudited)
- -------
Current assets:
      Cash and cash equivalents                                                   $5,303                    $4,741
      Receivables, less allowance for doubtful
      accounts of $659 ($1,437 at January 31, 2004)                               24,363                    23,931
      Inventories                                                                318,271                   239,748
      Other current assets                                                         6,266                     4,094
                                                                                --------                   --------
           Total current assets                                                  354,203                   272,514
      Property and equipment, less accumulated depreciation
       of $154,868 ($138,685 at January 31, 2004)                                142,359                   135,433
      Equipment under capital leases, less accumulated
       amortization of $3,622 ($3,169 at January 31,2004)                          1,346                     1,798
      Other noncurrent assets                                                      4,141                     4,005
                                                                                --------                   --------
           Total assets                                                         $502,049                  $413,750
                                                                                ========                  ========

LIABILITIES AND SHAREHOLDERS' EQUITY
Current liabilities:
      Accounts payable                                                           $91,088                   $74,799
      Accrued expenses and other                                                  20,814                    19,113
      Income taxes payable                                                         4,481                       930
      Current portion of indebtedness                                             11,800                        18
      Current portion of capital lease obligations                                   660                       725
      Current deferred income tax liability                                       13,506                    11,487
                                                                                --------                   --------
Total current liabilities                                                        142,349                   107,072
                                                                                 -------                   -------

Long-term portion of indebtedness, less current portion                           40,072                     5,603
Deferred income tax liability                                                      8,103                     6,335
Capital lease obligations, less current portion                                    1,178                     1,686
Other noncurrent liabilities                                                       2,406                     2,441
                                                                                --------                    ------
           Total liabilities                                                     194,108                   123,137
                                                                                --------                   -------

Shareholders' equity:
- ------------- -------
Preferred stock, nonvoting, no par value,
  10,000,000 shares authorized, none outstanding                                     ---                       ---
Preferred stock, Series A junior participating
   nonvoting, no par value, 224,594 shares
   authorized, none outstanding                                                      ---                       ---
Common stock, Class A voting, no par value,
   60,000,000 shares authorized, 39,329,065
   shares issued and outstanding
   (39,105,639 shares at January 31, 2004)                                       128,328                   126,430
Common stock, Class B nonvoting, no par value,
   11,500,000 shares authorized, none outstanding                                    ---                       ---
Retained earnings                                                                179,870                   164,183
Deferred compensation on restricted stock incentive plan                            (257)                      ---
                                                                                --------                   --------
           Total shareholders' equity                                            307,941                   290,613
                                                                                --------                   --------
      Total liabilities and shareholders' equity                                $502,049                  $413,750
                                                                                ========                  ========



     See accompanying notes to condensed consolidated financial statements.

                                       3


                                  FRED'S, INC.
                   CONDENSED CONSOLIDATED STATEMENTS OF INCOME
                                   (unaudited)
                    (in thousands, except per share amounts)


                                                                     

                                      Thirteen Weeks Ended         Thirty-nine Weeks Ended
                                      --------------------         -----------------------

                                    October 30,     November 1,    October 30,   November 1,
                                          2004            2003           2004         2003
                                    -----------     -----------    -----------   -----------

Net sales                             $349,139        $311,668     $1,031,475     $924,627
Cost of goods sold                     247,890         220,477        739,462      660,544
                                       -------         -------      ---------      --------

  Gross profit                         101,249          91,191        292,013      264,083
Selling, general and
 administrative expenses                89,986          77,303        264,287      231,533
                                       -------         -------       --------      --------

  Operating income                      11,263          13,888         27,726       32,550
Interest expense,net                       260              93            542          290
                                        ------         -------        -------      --------

  Income before income taxes            11,003          13,795         27,184       32,260
Provision for income taxes               3,482           4,767          9,145       10,990
                                        ------         -------         ------      --------

Net income                            $  7,521        $  9,028       $ 18,039     $ 21,270
                                      ========        ========       ========     ========

Net income per share
 Basic                                  $  .19        $    .23       $    .46     $    .55
                                        ======        ========       ========     ========

 Diluted                                $  .19        $    .23       $    .46     $    .54
                                        ======        ========       ========     ========

Weighted average shares outstanding
 Basic                                  39,220          38,901         39,130       38,680

 Effect of dilutive stock options          297             937            455          914
                                        ------           -----           ----        -----

 Diluted                                39,517          39,838         39,585       39,594
                                        ======          ======         ======       ======

Dividends per common share              $  .02          $  .02         $  .06       $  .06
                                        ======          ======         ======       ======


     See accompanying notes to condensed consolidated financial statements.


                                       4


                                  FRED'S, INC.
                 CONDENSED CONSOLIDATED STATEMENTS OF CASH FLOWS

                                   (unaudited)
                                 (in thousands)

                                                                                         

                                                                                Thirty-nine Weeks Ended
                                                                                -----------------------
                                                                              October 30,      November 1,
                                                                                  2004            2003
                                                                                  ----            ----

Cash flows from operating activities:
    Net income                                                                   $18,039        $21,270
    Adjustments to reconcile net income
    to net cash flows from operating activities:
      Depreciation and amortization                                               20,789         18,994
      Provision for uncollectible receivables                                        ---              1
Lifo reserve provision                                                             1,314          1,132
      Deferred income tax provision                                                3,787          3,226
      Amortization of deferred compensation on
        restricted stock incentive plan                                               59             35
    Tax benefit upon exercise of stock options                                       407          1,360
   (Increase)decrease in assets:
         Receivables                                                                (432)         1,571
         Inventories                                                             (79,837)       (68,215)
         Other assets                                                             (2,172)         2,824
    Increase (decrease) in liabilities:
      Accounts payable and accrued expenses                                       17,990         23,533
      Income taxes payable                                                         3,551            ---
      Other noncurrent liabilities                                                   (35)           300
                                                                                --------          -----
      Net cash (used in) provided by operating activities                        (16,540)         6,031
                                                                                --------          -----

Cash flows from investing activities:
    Capital expenditures                                                         (25,980)       (34,798)
    Asset acquisition (primarily intangibles)                                     (1,419)          (776)
                                                                                --------         ------
    Net cash used in investing activities                                        (27,399)       (35,574)
                                                                                --------        -------

Cash flows from financing activities:
    Reduction of indebtedness and capital lease obligations                         (586)          (710)
    Proceeds from revolving line of credit, net of payments                       46,264         19,284
    Proceeds from exercise of stock options                                        1,175          1,919
   Proceeds from sale of additional shares                                           ---          8,110
Repurchase of shares                                                                 ---         (2,646)
   Cash dividends paid                                                            (2,352)        (2,344)
                                                                                --------        --------
Net cash provided by financing activities                                         44,501         23,613
                                                                                --------        --------
    Increase (decrease) in cash and cash equivalents                                 562         (5,930)
    Beginning of period cash and cash equivalents                                  4,741          8,209
                                                                                --------        --------
    End of period cash and cash equivalents                                       $5,303         $2,279
                                                                                ========        ========

Supplemental disclosures of cash flow information:
    Interest paid                                                                   $452           $285
                                                                                    ====           ====
    Income taxes paid                                                             $1,400           $---
                                                                                  ======           ====


     See accompanying notes to condensed consolidated financial statements.

                                       5



                                  FRED'S, INC.
        NOTES TO CONDENSED CONSOLIDATED FINANCIAL STATEMENTS (Unaudited)

- --------------------------------------------------------------------------------
NOTE 1:  BASIS OF PRESENTATION
- --------------------------------------------------------------------------------

     Fred's,   Inc.  ("We",   "Our"  or  "Us")  operates  574  discount  general
merchandise stores, including 25 franchised Fred's stores, in fourteen states in
the southeastern  United States.  Two hundred and fifty-three of the stores have
full service pharmacies.

     The  accompanying  unaudited  consolidated  financial  statements have been
prepared in accordance  with the  instructions to Form 10-Q and therefore do not
include all information and notes necessary for a fair presentation of financial
position,  results of  operations  and cash flows in conformity  with  generally
accepted  accounting  principles.  The  statements  do reflect  all  adjustments
(consisting  of only  normal  recurring  accruals)  which are, in the opinion of
management,   necessary  for  a  fair  presentation  of  financial  position  in
conformity with generally accepted accounting principles.  The statements should
be read in conjunction with Notes to the Consolidated  Financial  Statements for
the fiscal year ended  January 31, 2004  incorporated  into Our Annual Report on
Form 10-K.

     The results of operations for the thirty-nine week period ended October 30,
2004 are not  necessarily  indicative of the results to be expected for the full
fiscal year.

     Certain prior quarter amounts have been reclassified to conform to the 2004
presentation.

- --------------------------------------------------------------------------------
NOTE 2:  INVENTORIES
- --------------------------------------------------------------------------------

     Warehouse  inventories  are stated at the lower of cost or market using the
FIFO (first-in, first-out) method. Retail inventories are stated at the lower of
cost or market as determined by the retail  inventory  method.  Under the retail
inventory method ("RIM"), the valuation of inventories at cost and the resulting
gross margin are calculated by applying a calculated cost-to-retail ratio to the
retail value of  inventories.  RIM is an  averaging  method that has been widely
used in the retail industry due to its practicality. Also, it is recognized that
the use of the RIM will result in valuing inventories at lower of cost or market
if  markdowns  are  currently  taken  as a  reduction  of the  retail  value  of
inventories.  Inherent in the RIM calculation are certain significant management
judgments and estimates including, among others, initial markups, markdowns, and
shrinkage,  which significantly impact the ending inventory valuation at cost as
well as resulting gross margin.  These significant  estimates,  coupled with the
fact that the RIM is an averaging  process,  can,  under certain  circumstances,
produce distorted or inaccurate cost figures.  Management  believes that our RIM
provides an inventory  valuation which reasonably  approximates cost and results
in carrying inventory at the lower of cost or market.

     For  pharmacy  inventories,  which are $35.2  million and $33.1  million at
October 30, 2004 and January 31, 2004,  respectively,  cost was determined using
the LIFO (last-in,  first-out) method. The current cost of inventories  exceeded
the LIFO cost by $9.1  million at October 30,  2004 and $7.8  million at January
31, 2004.  LIFO pharmacy  inventory  costs can only be determined  annually when
inflation  rates and inventory  levels are finalized;  therefore,  LIFO pharmacy
inventory costs for interim financial statements are estimated.

- --------------------------------------------------------------------------------
NOTE 3:  INCENTIVE STOCK OPTIONS
- --------------------------------------------------------------------------------

                                       6


We account for our  stock-based  compensation  plans using the  intrinsic  value
method prescribed in Accounting Principles Board Opinion No. 25, "Accounting for
Stock Issued to Employees," and related Interpretations. No stock-based employee
compensation  expense is reflected in net income  because the exercise  price of
our incentive  employee  stock options equals the market price of the underlying
stock on the date of grant.  The following  table  illustrates the effect on net
income and  earnings  per share if we had  applied  the fair  value  recognition
provisions of Statement of Financial  Accounting  Standards No. 123, "Accounting
for  Stock-Based   Compensation"   (SFAS  No.  123),  to  stock-based   employee
compensation.


                               Thirteen Weeks Ended   Thirty-nine Weeks Ended
                            October 30,  November 1,  October 30,   November 1,
                            -----------  -----------  -----------   -----------
                                2004        2003         2004          2003
                                ----        ----         ----          ----

                               (Amounts in thousands, except per share data)
                               ---------------------------------------------

Net income, as reported        $7,521      $9,028       $18,039      $21,270
SFAS No. 123 pro forma
compensation expense,
net of income taxes              (258)       (257)         (601)        (770)
                               -------     -------      --------     --------

SFAS No. 123 pro forma
Net income                    $ 7,263     $ 8,771      $ 17,438     $ 20,500
                              ========    ========     =========    =========



Earnings per share, as reported:
   Basic                       $ 0.19      $ 0.23         $ .46        $ .55
                               ======      ======         =====        =====
   Diluted                     $ 0.19      $ 0.23         $ .46        $ .54
                               ======      ======         =====        =====

Pro forma earnings per share:
   Basic                       $ 0.19      $ 0.23         $ .45        $ .55
                               ======      ======         =====        =====
   Diluted                     $ 0.18      $ 0.22         $ .44        $ .54
                               ======      ======         =====        =====



- --------------------------------------------------------------------------------
NOTE 4:  CHANGE IN ESTIMATE - INVENTORY SHRINKAGE
- --------------------------------------------------------------------------------

During the first quarter of fiscal 2004, we adopted a change in methodology  for
estimating  shrinkage to attain a more accurate  estimate of the shrink accrual.
This  change  decreased  net income  during the  quarter by  approximately  $0.2
million and increased net income year to date by approximately $0.5 million.



                                       7


Item 2:
                Management's Discussion and Analysis of Financial
                       Condition and Results of Operations

- --------------------------------------------------------------------------------
GENERAL
- --------------------------------------------------------------------------------

Executive Overview
- ------------------

In 2004,  the company has continued the strategic  direction that it implemented
in 2001 to grow its store base by  approximately  15% per year and achieve  same
store sales growth producing  strong earnings per share growth.  Fred's operates
574 discount  general  merchandise  stores in fourteen  states  primarily in the
southeastern United States. In the first three quarters of 2004, the company has
opened 66 new stores.  The majority of our new store  openings  were in Alabama,
Georgia, Florida, and South Carolina. We have not entered into any new states in
2004. Additionally, we have opened 13 new pharmacies during the year.

We continue to focus our  merchandising  and store  direction on  maintaining  a
competitive  differentiation  within the $25  shopping  trip.  Our unique  store
format and strategy  combine the attractive  element of a discount dollar store,
drug store and mass merchant. Our average customer transaction was approximately
$17.64.  In  comparison,  the discount  dollar stores  average $8 - $9 and chain
drugs and mass merchants average in the range of $40 - $80 per transaction.  Our
stores operate equally well in rural and urban markets. Our everyday low pricing
strategy is  supplemented  by 14  promotional  circulars  per year.  Our product
selection is enhanced by a private label program and opportunistic buys.

Although our comparable  sales  performance this year remains  positive,  it has
nonetheless fallen short of plan. With the significant added expense of gasoline
this year, our customers are more cautious in their spending and more focused on
lower-margin  merchandise,  and this impact is  reflected  in both our sales and
gross profit lines.  This, along with the unusual expenses  incurred as a result
of the  hurricanes  and  associated  clean-up,  as well as a surge in our  fuel,
transportation and utility expenses, led to the reduced financial results.

During the year, the Company has  implemented  program  improvements in employee
training, store POS systems upgrades,  allocation system upgrades, and SKU level
inventory management.

Our  business is subject to seasonal  influences,  but has tended to  experience
less seasonal  fluctuation  than many other retailers due to the mix of everyday
basic merchandise and pharmacy business.  Our fiscal fourth quarter is typically
the most profitable  quarter  because it includes the Christmas  selling season.
The overall strength of the fourth quarter is partially  mitigated,  however, by
the inclusion of the month of January,  which is generally the least  profitable
month of the year.

The impact of inflation on labor and occupancy  costs can  significantly  affect
our  operations.  Many of our  employees  are paid hourly  rates  related to the
federal  minimum wage and,  accordingly,  any increase  affects us. In addition,
payroll taxes,  employee benefits and other  employee-related  costs continue to
increase.  Occupancy costs,  including rent,  maintenance,  taxes and insurance,
also continue to rise. We believe that maintaining  adequate  operating  margins
through a combination of price adjustments and cost controls, careful evaluation
of occupancy  needs, and efficient  purchasing  practices are the most effective
tools for coping with increasing costs and expenses.

- --------------------------------------------------------------------------------
RESULTS OF OPERATIONS
- --------------------------------------------------------------------------------

Thirteen Weeks Ended October 30, 2004 and November 1, 2003
- ----------------------------------------------------------

                                       8


Net sales  increased to $349.1  million in 2004 from $311.7  million in 2003, an
increase of $37.4 million or 12.0%.  The increase was attributable to comparable
store  sales  increases  of 3.6%  ($11.2  million)  and sales by stores  not yet
included as comparable  stores ($27.2 million).  Sales to franchisees  decreased
$1.0 million in 2004.  The sales mix for the period was 51.8%  Hardlines,  34.0%
Pharmacy,  11.8%  Softlines,  and  2.4%  Franchise.  This  compares  with  49.6%
Hardlines,  34.1%  Pharmacy,  13.4%  Softlines,  and 2.9% Franchise for the same
period last year.  During the quarter,  17 new stores and 3 new pharmacies  were
opened and there were 2 store closings.

Gross profit decreased to 29.0% of sales in 2004 compared with 29.3% of sales in
the prior-year  period.  Gross profit margin decreased by 30 basis points in the
quarter  primarily from the continued shift of product mix toward more basic and
consumable  product.  Additionally,  last year's  gross margin  included  vendor
allowances  ($0.6 million) related to the Georgia  Distribution  Center startup.
The LIFO inventory effect on pharmacy inventories and gross margin returned to a
more normal level in the third quarter after a sharp increase experienced in the
last quarter.  These  increases were partial  offset by favorable  shrinkage (20
basis points) and double  coupon  expense (10 basis points) when compared to the
same period last year.

Selling,  general and administrative expenses increased to $90.0 million in 2004
from $77.3  million in 2003.  As a percentage  of sales,  expenses  increased to
25.8% of sales compared to 24.8% of sales last year. The increase in expenses is
primarily due to increases in store  occupancy  cost ($8.0 million) as a percent
of sales and cost  related to fuel  increases on  utilities  ($0.8  million) and
shipping  expenses ($1.0 million).  Also, in the quarter,  the pharmacy division
incurred an unusual  expense of  approximately  $.5 million  related to Medicare
reimbursements.

During the third  quarter  of 2004,  interest  expense,  net  increased  by $0.2
million when  compared to the 2003  quarter,  reflecting  additional  borrowings
during the quarter for the store growth program and inventory purchases.

For the third quarter of 2004, the effective income tax rate was 31.6%, compared
with 34.6% for last year. The lower income tax rate is a result of reduced state
taxes this year as compared to last year.

Thirty-nine Weeks Ended October 30, 2004 and November 1, 2003
- -------------------------------------------------------------

Net sales  increased to $1,031.5  million in 2004 from $924.6 million in 2003,an
increase of $106.9 million or 11.6%. The increase was attributable to comparable
store  sales  increases  of 3.3%  ($29.6  million)  and sales by stores  not yet
included as comparable  stores ($78.2 million).  Sales to franchisees  decreased
$0.9 million in 2004.  The sales mix for the period was 50.6%  Hardlines,  33.7%
Pharmacy,  13.3%  Softlines,  and  2.4%  Franchise.  This  compares  with  49.6%
Hardlines,  33.5%  Pharmacy,  14.1%  Softlines,  and 2.8% Franchise for the same
period  last year.  For the 2004 year to date we opened 66 new stores and 13 new
pharmacies and we closed 5 stores and 1 pharmacy.

Gross profit decreased to 28.3% of sales in 2004 compared with 28.6% of sales in
the prior-year  period.  Gross profit margins decreased as a result of sales mix
toward  more  basic and  consumable  products,  increased  freight  costs  ($0.2
million)  and an  increase  in the LIFO  inventory  reserve  ($0.9  million)  on
pharmacy  inventories.  During the first  quarter of 2004 we adopted a change in
methodology for estimating  shrinkage to attain a more accurate  estimate of the
shrink accrual.  This change  increased net income year to date by approximately
$0.5 million.

Selling, general and administrative expenses increased to $264.3 million in 2004
from $231.5  million in 2003.  As a percentage of sales,  expenses  increased to
25.6% of sales  compared to 25.1% of sales last year.  The increase is primarily
due to increases in store and pharmacy expenses as a percent of sales and higher
fuel cost.  These cost have been partially  offset by productivity  gains in the
distribution centers.

For the first nine months of 2004,  we incurred  interest  expense,  net of $0.5
million as compared to interest  expense,  net of $0.3  million  last year.  The

                                       9


difference is primarily  resulting from increased borrowing related to inventory
purchases and new store growth.

For the first  nine  months of 2004,  the  effective  income tax rate was 33.6%,
compared  with  34.1% for last  year.  The lower  income tax rate is a result of
reduced state taxes this year as compared to last year.  We  anticipate  the tax
rate for the balance of the year to remain in the 34% range.

- --------------------------------------------------------------------------------
LIQUIDITY AND CAPITAL RESOURCES
- --------------------------------------------------------------------------------

Due to the  seasonality  of our  business  inventories  are  generally  lower at
year-end.  However,  due to the  continued  increase in the number of stores and
pharmacies,  inventories are generally  higher at each  quarter-end than at each
quarter-end of the previous year.

Cash  flows  used in  operating  activities  totaled  $16.5  million  during the
thirty-nine  week period ended  October 30,  2004.  Cash was  primarily  used to
increase  inventories by approximately $79.8 million in the first nine months of
2004.  This  increase  was  primarily  attributable  to 66 new stores and 13 new
pharmacies  in the first  nine  months of 2004 as well as earlier  receiving  of
seasonal merchandise.

Cash flows used in investing  activities  totaled $27.4  million,  and consisted
primarily  of  capital  expenditures  associated  with the  store  and  pharmacy
expansion  program  ($21.4  million)  and for  technology  and  other  corporate
expenditures ($6.0 million).  During the first nine months, we opened 66 stores,
closed 5 stores,  opened 13  pharmacies,  closed 1  pharmacy  and  remodeled  29
stores. We expect to open approximately 80 to 85 stores for the year. For all of
fiscal 2004, the Company is planning capital expenditures totaling approximately
$35.0 million comprising approximately $26.1 million for upgrades,  remodels, or
new stores and pharmacies;  $6.9 million for technology  upgrades,  distribution
center equipment and capital  maintenance;  and $2.0 million for the acquisition
of customer lists and other pharmacy related items. Depreciation expense for the
year will be  approximately  $28 million.  Capital  expenditures in 2003 totaled
$48.0 million and depreciation expense was $25.7 million.

Cash flows provided by financing  activities  totaled $44.5 million and included
$46.3 million of borrowings under the Company's revolver for inventory needs.

On July 31, 2003,  we entered into the third loan  modification  agreement  (the
"Agreement") to modify the April 3, 2000 Revolving Loan and Credit Agreement, as
amended.  The Agreement  provides us with an unsecured  revolving line of credit
commitment of up to $40 million and bears interest at a 1.5% below prime rate or
a LIBOR-based  rate. Under the most restrictive  covenants of the Agreement,  we
are required to maintain specified  shareholders' equity (which was $256,697,000
at October 30, 2004) and net income levels.  We are required to pay a commitment
fee to the bank at a rate per annum equal to .15% on the  unutilized  portion of
the revolving line  commitment  over the term of the Agreement.  The term of the
Agreement  extends to July 31,  2006.  There were  $40.0  million in  borrowings
outstanding  at October 30, 2004 and $5.5 million in borrowings  outstanding  at
January 31, 2004.

On  June  28,  2004,  the  Company  and a bank  entered  into  the  fourth  loan
modification  agreement(the "2004 Temporary Overline #1") to modify the April 3,
2000  Revolving  Loan and Credit  Agreement,  as  amended  to grant a  temporary
extension of the commitment. The 2004 Temporary Overline #1 provides the Company
with a one  hundred and eighty day  unsecured  loan of $10.0  million.  The 2004

                                       10


Temporary  Overline #1 bears  interest at 1.5% below prime rate. The bank agreed
to forego the commitment fee on the unutilized portion of the Temporary Overline
#1.  Borrowings  outstanding  under this 2004 Temporary  Overline  totaled $10.0
million at October 30, 2004 and will mature on December 28, 2004.

On  October  19,  2004,  the  Company  and a bank  entered  into the fifth  loan
modification  agreement(the "2004 Temporary Overline #2") to modify the April 3,
2000  Revolving  Loan and Credit  Agreement,  as  amended  to grant a  temporary
extension of the commitment. The 2004 Temporary Overline #2 provides the Company
with a  fifty-seven  day unsecured  loan of $10.0  million.  The 2004  Temporary
Overline #2 bears  interest at 1.5% below prime rate.  The bank agreed to forego
the  commitment  fee on the  unutilized  portion of the  Temporary  Overline #2.
Borrowings  outstanding  under this 2004  Temporary  Overline  #2  totaled  $1.8
million at October 30, 2004 and will mature on December 15, 2004.

We believe that cash flows during the 4th quarter should be sufficient to retire
both overlines.

We  believe  that  sufficient  capital  resources  are  available  in  both  the
short-term  and long-term  through  currently  available cash and cash generated
from future  operations  and,  if  necessary,  the ability to obtain  additional
financing.

- --------------------------------------------------------------------------------
RECENT ACCOUNTING PRONOUNCEMENTS
- --------------------------------------------------------------------------------

In early 2004, the Financial  Accounting  Standards Board ("FASB")  adopted FASB
Staff Position No. FSP 106-2, "Accounting and Disclosure Requirements Related to
the Medicare Prescription Drug, Improvement and Modernization Act of 2003." This
pronouncement  does  not  have a  material  impact  on the  Company's  financial
statements as a whole.

On November 24, 2004, the FASB issued FASB Statement No. 151,  Inventory Costs -
An  Amendment  of ARB No. 43,  Chapter 4. This new  standard  is the result of a
broader  effort  by the  FASB to  improve  financial  reporting  by  eliminating
differences  between GAAP in the United  States and GAAP  developed by the IASB.
Statement 151 clarifies that abnormal amounts of idle facility expense, freight,
handling  costs and spoilage  should be expensed as incurred and not included in
overhead.  Further,  Statement 151 requires that allocation of fixed  production
overheads  to  conversion  costs  should  be based  on  normal  capacity  of the
production  facilities.  The  provisions  in  Statement  151 are  effective  for
inventory  costs  incurred  during fiscal years  beginning  after June 15, 2005.
Companies must apply the standard  prospectively.  We have not yet evaluated the
impact of this new standard on our prospective financial statements.

- --------------------------------------------------------------------------------
CAUTIONARY STATEMENT REGARDING FORWARD-LOOKING INFORMATION
- --------------------------------------------------------------------------------

Other than statements based on historical  facts,  many of the matters discussed
in this Form 10-Q relate to events  which we expect or  anticipate  may occur in
the future.  Such statements are defined as  "forward-looking  statements" under
the Private  Securities  Litigation  Reform Act of 1995 (the "Reform  Act"),  15
U.S.C.A.  Sections 77z-2 and 78u-5 (Supp.  1996).  The Reform Act created a safe
harbor to protect  companies from  securities  law liability in connection  with
forward-looking  statements.  Fred's Inc. ("Fred's" or the "Company") intends to
qualify  both its written and oral  forward-looking  statements  for  protection
under the Reform Act and any other similar safe harbor provisions.

The words "believe",  "anticipate",  "project",  "plan",  "expect",  "estimate",
"objective",  "forecast",  "goal",  "intend",  "will  likely  result",  or "will

                                       11


continue" and similar expressions generally identify forward-looking statements.
All  forward-looking  statements are inherently  uncertain,  and concern matters
that involve risks and other factors which may cause the actual  performance  of
the Company to differ  materially from the  performance  expressed or implied by
these statements.  Therefore,  forward-looking statements should be evaluated in
the context of these uncertainties and risks, including but not limited to:

    o Economic and weather  conditions which affect buying patterns of our
      customers and supply chain efficiency;

    o Changes in  consumer  spending  and our  ability  to  anticipate buying
      patterns and implement appropriate inventory strategies;

    o  Continued availability of capital and financing;

    o  Competitive factors;

    o  Changes in reimbursement practices for pharmaceuticals;

    o  Governmental regulation;

    o  Increases in fuel and utility rates;

    o Other factors affecting business beyond our control.

Consequently,  all  forward-looking  statements are qualified by this cautionary
statement. We undertake no obligation to update any forward-looking statement to
reflect events or circumstances arising after the date on which it was made.

Item 3.

- --------------------------------------------------------------------------------
QUANTITATIVE AND QUALITATIVE DISCLOSURE ABOUT MARKET RISK
- --------------------------------------------------------------------------------

We have no holdings of  derivative  financial  or  commodity  instruments  as of
October 30, 2004. We are exposed to financial market risks, including changes in
interest  rates.  All  borrowings  under our  Revolving  Credit  Agreement  bear
interest at 1.5% below prime rate or a LIBOR-based rate. An increase in interest
rates of 100 basis points would not significantly  affect our income. All of our
business is transacted in U.S. dollars and,  accordingly,  foreign exchange rate
fluctuations  have  never  had a  significant  impact  on us,  and  they are not
expected to in the foreseeable future.

Item 4.

- --------------------------------------------------------------------------------
CONTROLS AND PROCEDURES
- --------------------------------------------------------------------------------

As of the end of the period covered by this report,  the Company  carried out an
evaluation,  under  the  supervision  and with the  participation  of our  Chief
Executive  Officer and Chief  Financial  Officer,  of the  effectiveness  of the
Company's  disclosure  controls and  procedures  (as defined in Rules  13a-15(e)
under the  Securities  Exchange Act of 1934, as amended (the  "Exchange  Act")).
Based on that  evaluation,  the Chief Executive  Officer and the Chief Financial
Officer,  concluded  that,  as of the date of their  evaluation,  the  Company's
disclosure  controls and  procedures  are  effective in timely  alerting them to
material  information  required  to be included in the  Company's  periodic  SEC
reports.   Consistent  with  the  suggestion  of  the  Securities  and  Exchange
Commission,  the Company has formed a  Disclosure  Committee  consisting  of key
Company  personnel  designed  to review the  accuracy  and  completeness  of all
disclosures  made by the Company.  Although  during this fiscal year the Company

                                       12


has instituted  various changes to enhance its internal  controls over financial
reporting,  there have been no changes during the quarter ended October 30, 2004
in the Company's internal control over financial  reporting that have materially
affected,  or are reasonably likely to materially affect, the Company's internal
control over financial reporting.

As  required  by  Section  404  of  the  Sarbanes-Oxley  Act,  the  Company  has
substantially   completed  documenting  its  internal  control  structure.   The
evaluation  of the  documentation  and  ongoing  testing  has  revealed  certain
weaknesses  in  internal  controls  that  require  remediation.  The Company has
remediated, or is in the process of remediating these weaknesses.  None of these
weaknesses  have  materially  affected or are  reasonably  likely to  materially
affect the Company's internal control over financial reporting. We will continue
to  evaluate  our  internal  control  structure  through  the end of the testing
process, and will take remedial action where possible. In areas where weaknesses
were discovered and remediation was necessary, further testing will be conducted
to ensure that the remediation  was effective.  The Company will continue in the
fourth quarter to implement  enhancements to its internal  control  structure in
preparation for compliance with Section 404 of the Sarbanes-Oxley Act.






                                       13


                           PART II. OTHER INFORMATION


Item 1.   Legal Proceedings

             Not Applicable.

Item 2.   Changes in Securities

             Not Applicable.

Item 3.   Defaults Upon Senior Securities

             Not Applicable.

Item 4.   Submission of Matters to a Vote of Securities Holders

             Not Applicable.

Item 6.   Exhibits and Reports on Form 8-K

             Exhibits:

                10.16     Fourth modification agreement dated June 28, 2004
                          modifying the Revolving Loan and Credit Agreement to
                          grant a temporary overline.
                10.17     Fifth  modification  agreement dated October 19, 2004
                          modifying the  Revolving  Loan and Credit Agreement to
                          grant a temporary overline.
                31.1      Certification of Chief Executive Officer.
                31.2      Certification of Chief Financial Officer.
                32.0      Certification of Chief Executive Officer and Chief
                          Financial Officer pursuant to 18 U.S.C. Section 1350.

             Reports on Form 8-K:

                          1)  Form 8-K dated August 26, 2004 with press release
                              dated August 26, 2004, reporting its
                              quarterly earnings result for its second quarter
                              ended July 31, 2004.




                                       14



                                   SIGNATURES

     Pursuant to the  requirements  of the Securities  Exchange Act of 1934, the
registrant  has duly  caused  this  report  to be  signed  on its  behalf by the
undersigned thereunto duly authorized.

                                                   FRED'S, INC.

                                                   /s/Michael J. Hayes
                                                   ---------------------------
                                                   Michael J. Hayes
Date:  December 7, 2004                            Chief Executive Officer
- -----------------------




                                                   /s/Jerry A. Shore
                                                   ---------------------------
                                                   Jerry A. Shore
Date:  December 7, 2004                            Chief Financial Officer
- -----------------------













                                       15


                                                                   Exhibit 10.16


                          FOURTH MODIFICATION AGREEMENT
                   OF THE REVOLVING LOAN AND CREDIT AGREEMENT



     THIS  FOURTH  MODIFICATION  AGREEMENT  OF THE  REVOLVING  LOAN  AND  CREDIT
AGREEMENT (hereafter the "Fourth  Modification") made and entered into this 28th
day of June,  2004,  to be  effective as of the 28th day of June,  2004,  by and
between UNION PLANTERS BANK NATIONAL ASSOCIATION, a national banking association
with its principal office at 6200 Poplar Avenue, Memphis,  Tennessee ("Lender"),
SUNTRUST BANK, a Georgia banking  corporation  with its principal office at 6410
Poplar Avenue,  Suite 320, Memphis,  Tennessee (the "Documentation  Agent"), and
FRED'S,  INC., a Tennessee  corporation having its principal offices at 4300 New
Getwell Road, Memphis, Tennessee (the "Borrower").

     WHEREAS,  Borrower  is justly  indebted  to  Lender  for  Advances  made to
Borrower  evidenced  by that  certain  Promissory  Note dated April 3, 2000 (the
"Note"), in the original principal amount of Forty Million Dollars ($40,000,000)
and that certain Credit Agreement dated March 28, 2000,  effective April 3, 2000
(herein the "Credit Agreement"), providing for advances up to a maximum of Forty
Million Dollars ($40,000,000);

     WHEREAS,  Borrower and Lender  entered into a  Modification  Agreement (the
"First  Modification") dated May 26, 2000,  providing,  among other things, that
the Note,  originally payable on demand,  would mature and be due and payable on
April 3, 2003;

     WHEREAS,  Borrower and Lender entered into a second Modification  Agreement
(the "Second Modification") dated April 30, 2002, providing, among other things,
that the Note would be due and payable on March 31, 2004;

     WHEREAS,  Borrower and Lender entered into a third  Modification  Agreement
(the "Third Modification") dated July 31, 2003,  providing,  among other things,
that the Note would be due and payable on July 31, 2006; and

     WHEREAS,  Borrower and Lender desire to amend the Credit Facility, to grant
a temporary extension of the Commitment in the amount of Ten Millions and 00/100
Dollars  ($10,000,000.00) (the "Temporary Overline"),  causing the Commitment to
temporarily  increase from Forty Million and 00/100 Dollars  ($40,000,000.00) to
Fifty Million and 00/100 Dollars ($50,000,000.00).

     NOW  THEREFORE,  in  consideration  of the  premises  and of other good and
valuable   consideration,   the   adequacy  and  receipt  of  which  are  hereby
acknowledged, the parties hereto agree as follows:

         1.    Temporary   Increase   of   Commitment:   Borrower,   Lender  and
               Documentation  Agent  each  agree  that the  Commitment  shall be
               temporarily  increased by the amount of the  Temporary  Overline,
               effective June 28, 2004, and that the Temporary Overline shall be
               immediately due and payable as of December 28, 2004 ( such period
               of time to be referred to as the "Temporary  Term").  The parties
               agree that the Temporary Overline shall be governed by all terms,
               conditions  and  covenants  currently  in place  for the Note and
               Credit Facility,  other than with respect to the maturity date as
               set forth in this paragraph 1 of the Fourth Modification.

         2.    Notation:  Lender and  Documentation  Agent covenant and agree to
               make a notation upon their  respective  records  showing that the
               Note and Agreement has been modified as set forth herein.



         3.    Origination  Fee. In  consideration of the grant of the Temporary
               Overline  by  Lender,  Borrower  shall  pay  an  origination  fee
               ("Origination  Fee") in an amount  equal to ten basis  points (10
               bp) of the Temporary  Overline,  equaling the sum of Ten Thousand
               and 00/1000 Dollars ($10,000.00).

         4.    Suspension  of "Unused"  Fee. For only such time as the Temporary
               Term is in  effect,  the  "unused"  fee shall be  suspended  with
               respect to the Temporary  Overline.  The preceding sentence shall
               not apply to the original Commitment amount.

         5.    Continuation of Terms. All of the terms, covenants and conditions
               of the Note,  as modified by the First  Modification,  the Second
               Modification  and Third  Modification and the Credit Agreement or
               any other document executed in connection therewith,  are, to the
               extent   not   inconsistent   with  the  terms   herein,   hereby
               incorporated herein by reference.  It is expressly understood and
               agreed  that  the  terms,   covenants   and   conditions  of  all
               instruments  evidencing or securing the indebtedness evidenced by
               the Note shall  remain in full force and effect,  and shall in no
               manner be affected by the  execution of this Fourth  Modification
               except as the same are expressly  modified herein.  It is further
               expressly  understood and agreed that the Participation Period of
               Documentation  Agent, as set forth in that certain  Participation
               Agreement,  by and  between  the  parties,  dated as of March 28,
               2000, shall be extended and remain in full force and effect,  and
               shall terminate on July 31, 2006. Furthermore, Borrower presently
               covenants,  represents  and warrants  that it is full and current
               compliance  with all  covenants,  representations  and warranties
               contained in the Credit Agreement.

         6.    Incorporation  by Reference.  The parties  hereby  incorporate by
               reference  the  Credit  Agreement,  First  Modification,   Second
               Modification, Third Modification and Participation Agreement, all
               attached hereto as Exhibits "A", "B", "C" and "D",  respectively,
               as though each agreement was set forth in its entirety.

         7.    No   Discharge.   The  execution  and  delivery  of  this  Fourth
               Modification does not discharge the obligors, sureties, endorsers
               or guarantors of the Note,  and all rights of the Lender  against
               any and all of same are expressly reserved.

         8.    Successors in Interest. This Fourth Modification shall be binding
               upon and  inure  to the  benefit  of the  parties  hereto,  their
               respective successors and assigns, transferrees and grantees.

         9.    Governing  Law:  This Fourth  Modification  shall be construed in
               accordance  with  the  laws of the  State  of  Tennessee  and the
               parties  hereto  subject   themselves  to  the   jurisdiction  of
               Tennessee and venue of the Courts of Shelby County, Tennessee for
               the resolution of any dispute hereunder.

         10.   Undefined Terms:  All capitalized  terms not defined herein shall
               have the same definitions as set forth in the Credit Agreement.



                  [Remainder of page left intentionally blank.]





IN WITNESS WHEREOF, the parties have executed this Fourth Modification Agreement
of the  Revolving  Loan and Credit  Agreement as of the day and year first above
written.

                                    BORROWER:

                                    FRED'S INC., a Tennessee corporation



                                    By:      /s/ Jerry A. Shore
                                           -------------------------------
                                    Name:  Jerry A. Shore
                                    Title: Executive Vice President and Chief
                                           Financial Officer




                                    LENDER:

                                    UNION PLANTERS BANK NATIONAL ASSOCIATION



                                    By:    /s/ James Gummel
                                        ------------------------------------
                                               James Gummel
                                               Senior Vice President


                                    DOCUMENTATION AGENT:

                                    SUNTRUST BANK, a Georgia banking corporation



                                    By:     /s/ Bryan W. Ford
                                         ------------------------------------
                                    Name:         Bryan W. Ford
                                          -----------------------------------
                                    Title:        Director
                                          -----------------------------------

STATE OF TENNESSEE

COUNTY OF SHELBY

     Before me  personally  appeared,  James  Gummel,  with whom I am personally
acquainted (or proved to me on the basis of satisfactory evidence) and who, upon
oath,  acknowledged  himself to be a Sr. Vice  President of UNION  PLANTERS BANK
NATIONAL  ASSOCIATION,  and that he as such officer being duly  authorized so to
do,  executed the  foregoing  instrument  for the purpose  therein  contained by
signing the name of the bank by himself as such officer.

     WITNESS MY HAND AND OFFICIAL SEAL, at office this 2nd day of July, 2004.


                                         /s/ Patricia A. Robinson
                                       --------------------------------------
                                                   Notary Public
My Commission Expires:

August 28, 2007
- ---------------------




STATE OF TENNESSEE

COUNTY OF SHELBY


     Before me personally  appeared,  Jerry A. Shore,  with whom I am personally
acquainted (or proved to me on the basis of satisfactory evidence) and who, upon
oath,  acknowledged himself to be the Chief Financial Officer of FRED'S, INC., a
Tennessee  corporation,  and that he as such officer being duly authorized so to
do,  executed the  foregoing  instrument  for the purpose  therein  contained by
signing the name of the company by himself as such officer.

     WITNESS MY HAND AND  OFFICIAL  SEAL,  at office this 29th day of June,
2004.


                                       /s/ Merle S. McGruder
                                    ---------------------------------------
                                                 Notary Public
My Commission Expires:

January 29, 2008
- -----------------------

STATE OF TENNESSEE

COUNTY OF SHELBY

     Before me  personally  appeared,  Bryan W. Ford,  with whom I am personally
acquainted (or proved to me on the basis of satisfactory evidence) and who, upon
oath,  acknowledged himself to be a Director of SUNTRUST BANK, a Georgia banking
corporation,  and  that he as  such  officer  being  duly  authorized  so to do,
executed the foregoing  instrument for the purpose therein  contained by signing
the name of the bank by himself as such officer.

     WITNESS MY HAND AND OFFICIAL  SEAL, at office this 2 day of July, 2004.


                                    /s/ Shermin Cherry
                                 --------------------------------------
                                             Notary Public

My Commission Expires:

October 26, 2004
- -----------------------




                                   EXHIBIT "A"

                                Credit Agreement
                                ----------------




                                   EXHIBIT "B"

                          First Modification Agreement
                          ----------------------------






                                   EXHIBIT "C"

                          Second Modification Agreement
                          -----------------------------






                                   EXHIBIT "D"

                          Third Modification Agreement
                          ----------------------------







                                   EXHIBIT "E"

                             Participation Agreement
                             -----------------------






                                                                   Exhibit 10.17

                          FIFTH MODIFICATION AGREEMENT
                   OF THE REVOLVING LOAN AND CREDIT AGREEMENT



     THIS  FIFTH  MODIFICATION  AGREEMENT  OF  THE  REVOLVING  LOAN  AND  CREDIT
AGREEMENT  (hereafter the "Fifth  Modification") made and entered into this 19th
day of October,  2004,  to be effective as of the 20th day of October,  2004, by
and  between  UNION  PLANTERS  BANK  NATIONAL  ASSOCIATION,  a national  banking
association with its principal office at 6200 Poplar Avenue, Memphis,  Tennessee
("Lender"),  SUNTRUST  BANK, a Georgia  banking  corporation  with its principal
office at 6410 Poplar Avenue, Suite 320, Memphis,  Tennessee (the "Documentation
Agent"), and FRED'S, INC., a Tennessee  corporation having its principal offices
at 4300 New Getwell Road, Memphis, Tennessee (the "Borrower").

     WHEREAS,  Borrower  is justly  indebted  to  Lender  for  Advances  made to
Borrower  evidenced  by that  certain  Promissory  Note dated April 3, 2000 (the
"Note"), in the original principal amount of Forty Million Dollars ($40,000,000)
and that certain Credit Agreement dated March 28, 2000,  effective April 3, 2000
(herein the "Credit Agreement"), providing for advances up to a maximum of Forty
Million Dollars ($40,000,000);

     WHEREAS,  Borrower and Lender  entered into a  Modification  Agreement (the
"First  Modification") dated May 26, 2000,  providing,  among other things, that
the Note,  originally payable on demand,  would mature and be due and payable on
April 3, 2003;

     WHEREAS,  Borrower and Lender entered into a second Modification  Agreement
(the "Second Modification") dated April 30, 2002, providing, among other things,
that the Note would be due and payable on March 31, 2004;

     WHEREAS,  Borrower and Lender entered into a third  Modification  Agreement
(the "Third Modification") dated July 31, 2003,  providing,  among other things,
that the Note would be due and payable on July 31, 2006;

     WHEREAS,  Borrower and Lender entered into a fourth Modification  Agreement
(the "Fourth Modification") dated June 28, 2004, providing,  among other things,
that  the  Note  would  be  increased  to  Fifty  Million  and  00/100   Dollars
($50,000,000.00)  until  December  15,  2004,  at which  time it will  revert to
$40,000,000.00 until July 31 2006; and

     WHEREAS,  Borrower and Lender desire to amend the Credit  Facility,  and to
grant an additional  temporary increase in the Commitment,  in the amount of Ten
Million and 00/100 Dollars  ($10,000,000.00) (in addition to and having the same
maturity as the increase  created by the Fourth  Modification)  (the  "Temporary
Overline"),  causing the Commitment to  temporarily  increase from Forty Million
and  00/100  Dollars  ($40,000,000.00)  to  Sixty  Million  and  00/100  Dollars
($60,000,000.00).

     NOW  THEREFORE,  in  consideration  of the  premises  and of other good and
valuable   consideration,   the   adequacy  and  receipt  of  which  are  hereby
acknowledged, the parties hereto agree as follows:

     1.   Temporary Increase of Commitment:  Borrower,  Lender and Documentation
          Agent each agree that the Commitment shall be temporarily increased by
          the amount of the Temporary Overline,  effective October 20, 2004, and
          that the Temporary Overline shall be immediately due and payable as of
          December  15,  2004  (such  period  of time to be  referred  to as the
          "Temporary Term"). The parties agree that the Temporary Overline shall
          be governed by all terms,  conditions and covenants currently in place
          for the Note and  Credit  Facility,  other  than with  respect  to the
          maturity  date  as  set  forth  in  this  paragraph  1 of  the  Fourth
          Modification.



     2.   Notation:  Lender and Documentation Agent covenant and agree to make a
          notation  upon  their  respective  records  showing  that the Note and
          Agreement has been modified as set forth herein.

     3.   Origination  Fee.  In  consideration  of the  grant  of the  Temporary
          Overline   by  Lender,   Borrower   shall  pay  an   origination   fee
          ("Origination Fee") in an amount equal to twenty basis points (20 bps)
          of the  Temporary  Overline,  equaling the sum of Twenty  Thousand and
          00/1000 Dollars ($20,000.00).

     4.   Suspension of "Unused"  Fee. For only such time as the Temporary  Term
          is in effect,  the "unused" fee shall be suspended with respect to the
          Temporary  Overline.  The  preceding  sentence  shall not apply to the
          original Commitment amount.

     5.   Continuation of Terms.  All of the terms,  covenants and conditions of
          the  Note,  as  modified  by  the  First   Modification,   the  Second
          Modification,  Third  Modification  and  Fourth  Modification  and the
          Credit  Agreement  or  any  other  document   executed  in  connection
          therewith,  are, to the extent not inconsistent with the terms herein,
          hereby  incorporated herein by reference.  It is expressly  understood
          and agreed that the terms, covenants and conditions of all instruments
          evidencing  or securing the  indebtedness  evidenced by the Note shall
          remain in full force and effect, and shall in no manner be affected by
          the  execution  of this  Fourth  Modification  except  as the same are
          expressly  modified  herein.  It is further  expressly  understood and
          agreed that the  Participation  Period of Documentation  Agent, as set
          forth in that  certain  Participation  Agreement,  by and  between the
          parties,  dated as of March 28, 2000,  shall be extended and remain in
          full  force  and  effect,  and  shall  terminate  on  July  31,  2006.
          Furthermore,  Borrower  presently  covenants,  represents and warrants
          that  it  is  full  and  current   compliance   with  all   covenants,
          representations and warranties contained in the Credit Agreement.

     6.   Incorporation  by  Reference.   The  parties  hereby   incorporate  by
          reference   the   Credit   Agreement,   First   Modification,   Second
          Modification,    Third    Modification,    Fourth   Modification   and
          Participation Agreement.

     7.   No Discharge.  The  execution and delivery of this Fifth  Modification
          does not discharge the obligors,  sureties, endorsers or guarantors of
          the Note, and all rights of the Lender against any and all of same are
          expressly reserved.

     8.   Successors in Interest.  This Fifth Modification shall be binding upon
          and inure to the  benefit  of the  parties  hereto,  their  respective
          successors and assigns, transferees and grantees.

     9.   Governing  Law:  This  Fifth   Modification   shall  be  construed  in
          accordance  with the laws of the State of  Tennessee  and the  parties
          hereto subject  themselves to the  jurisdiction of Tennessee and venue
          of the Courts of Shelby  County,  Tennessee for the  resolution of any
          dispute hereunder.

     10.  Undefined Terms:  All capitalized  terms not defined herein shall have
          the same definitions as set forth in the Credit Agreement.

                  [Remainder of page left intentionally blank.]




IN WITNESS WHEREOF, the parties have executed this Fourth Modification Agreement
of the  Revolving  Loan and Credit  Agreement as of the day and year first above
written.

                                    BORROWER:

                                    FRED'S INC., a Tennessee corporation



                                    By:    /s/ Jerry A. Shore
                                          -------------------------------

                                    Name:   Jerry A. Shore
                                          -------------------------------

                                    Title:  EVP & CFO
                                           ------------------------------



                                    LENDER:

                                    UNION PLANTERS BANK NATIONAL ASSOCIATION



                                    By:   /s/ James Gummel
                                        ---------------------------------

                                             James Gummel
                                             Senior Vice President

                                    DOCUMENTATION AGENT:

                                    SUNTRUST BANK, a Georgia banking corporation



                                    By:    /s/ Bryan W. Ford
                                        ---------------------------------

                                    Name:     Bryan W. Ford
                                           ------------------------------

                                    Title      Director
                                           ------------------------------

STATE OF TENNESSEE

COUNTY OF SHELBY

     Before me personally appeared,  James Gummel,  with whom I
am personally acquainted (or proved to me on the basis of satisfactory evidence)
and who, upon oath, acknowledged himself to be a Sr. Vice President of
UNION PLANTERS BANK NATIONAL ASSOCIATION, and that he as such officer being duly
authorized so to do,  executed the foregoing  instrument for the purpose therein
contained by signing the name of the bank by himself as such officer.

     WITNESS MY HAND AND OFFICIAL  SEAL,  at office this 19th day of October,
2004.


                                    /s/ Patricia A. Robinson
                                 --------------------------------------
                                             Notary Public


My Commission Expires:

August 28, 2007
- -----------------------






STATE OF TENNESSEE

COUNTY OF SHELBY


     Before me personally  appeared,  Jerry A. Shore,  with whom I am personally
acquainted (or proved to me on the basis of satisfactory evidence) and who, upon
oath,  acknowledged himself to be the Chief Financial Officer of FRED'S, INC., a
Tennessee  corporation,  and that he as such officer being duly authorized so to
do,  executed the  foregoing  instrument  for the purpose  therein  contained by
signing the name of the company by himself as such officer.

     WITNESS MY HAND AND  OFFICIAL  SEAL,  at office this 19th day of October,
2004.


                                /s/ Judith A. Jones
                               ---------------------------------------
                                            Notary Public

My Commission Expires:

June 7, 2005
- -----------------------




STATE OF TENNESSEE

COUNTY OF SHELBY

     Before me  personally  appeared,  Bryan W. Ford,  with whom I am personally
acquainted (or proved to me on the basis of satisfactory evidence) and who, upon
oath,  acknowledged himself to be a Director of SUNTRUST BANK, a Georgia banking
corporation,  and  that he as  such  officer  being  duly  authorized  so to do,
executed the foregoing  instrument for the purpose therein  contained by signing
the name of the bank by himself as such officer.

     WITNESS MY HAND AND OFFICIAL  SEAL, at office this 19 day of October,
2004.


                                     /s/ Shermin Cherry
                                 --------------------------------------
                                              Notary Public

My Commission Expires:

October 26, 2004
- -----------------------




                                   EXHIBIT "A"

                                Credit Agreement
                                ----------------




                                   EXHIBIT "B"

                          First Modification Agreement
                          ----------------------------




                                   EXHIBIT "C"

                          Second Modification Agreement
                          -----------------------------




                                   EXHIBIT "D"

                          Third Modification Agreement
                          ----------------------------




                                   EXHIBIT "E"

                          Fourth Modification Agreement
                          -----------------------------




                                   EXHIBIT "F"

                             Participation Agreement
                             ------------------------







                                                                    Exhibit 31.1

                    CERTIFICATION OF CHIEF EXECUTIVE OFFICER

I, Michael J. Hayes, certify that:

    1.    I have reviewed this quarterly report on Form 10-Q of Fred's, Inc.;

    2.    Based on my  knowledge,  this  report  does  not  contain  any  untrue
          statement  of a  material  fact  or  omit to  state  a  material  fact
          necessary to make the statements  made, in light of the  circumstances
          under which such  statements were made, not misleading with respect to
          the period covered by this report;

    3.    Based on my knowledge,  the financial statements,  and other financial
          information  included in this report,  fairly  present in all material
          respects the financial condition, results of operations and cash flows
          of the  registrant  as of,  and for,  the  periods  presented  in this
          report;

    4.    The registrant's  other  certifying  officer and I are responsible for
          establishing  and maintaining  disclosure  controls and procedures (as
          defined in Exchange Act Rules  13a-15(e) and  15d-15(e))  and internal
          control  over  financial  reporting  (as defined in Exchange Act Rules
          13a-15(f) and 15d-15(f) for the registrant and have:

          a)   Designed such disclosure controls and procedures,  or caused such
               disclosure  controls and  procedures to be  designated  under our
               supervision,  to ensure that material information relating to the
               registrant,  including  its  consolidated  subsidiaries,  is made
               known to us by others within those entities,  particularly during
               the period in which this report is being prepared;

          b)   Designated  such internal  control over financial  reporting,  or
               caused such  internal  control  over  financial  reporting  to be
               designed under our supervision,  to provide reasonable  assurance
               regarding  the   reliability  of  financial   reporting  and  the
               preparation  of financial  statements  for  external  purposes in
               accordance with generally accepted accounting principles;

          c)   Evaluated  the  effectiveness  of  the  registrant's   disclosure
               controls  and   procedures  and  presented  in  this  report  our
               conclusions  about the  effectiveness of the disclosure  controls
               and  procedures,  as of the  end of the  period  covered  by this
               report based on such evaluation; and

          d)   Disclosed in this report any change in the registrant's  internal
               control  over  financial   reporting  that  occurred  during  the
               registrant's  most  recent  fiscal  quarter  that has  materially
               affected,  or is  reasonably  likely to  materially  affect,  the
               registrant's internal control over financial reporting; and

    5.    The registrant's other certifying officer and I have disclosed,  based
          on our most recent  evaluation  of  internal  control  over  financial
          reporting,  to the  registrant's  auditors and the audit  committee of
          registrant's board of directors:

          b)   All  significant  deficiencies  and  material  weaknesses  in the
               design or operation of internal control over financial  reporting
               which are reasonably  likely to adversely affect the registrant's
               ability  to  record,  process,  summarize  and  report  financial
               information; and

          c)   Any fraud,  whether or not material,  that involves management or
               other employees who have a significant  role in the  registrant's
               internal control over financial reporting.

Date: December 7, 2004                     /s/ Michael J. Hayes
                                           ----------------------------------
                                           Michael J. Hayes
                                           Chief Executive Officer




                                                                    Exhibit 31.2

                    CERTIFICATION OF CHIEF FINANCIAL OFFICER

I, Jerry A. Shore, certify that:

    1.    I have reviewed this quarterly report on Form 10-Q of Fred's, Inc.

    2.    Based on my  knowledge,  this  report  does  not  contain  any  untrue
          statement  of a  material  fact  or  omit to  state  a  material  fact
          necessary to make the statements  made, in light of the  circumstances
          under which such  statements were made, not misleading with respect to
          the period covered by this report;

    3.    Based on my knowledge,  the financial statements,  and other financial
          information  included  in  report,  fairly  present  in  all  material
          respects the financial condition, results of operations and cash flows
          of the  registrant  as of,  and for,  the  periods  presented  in this
          report;

    4.    The registrant's  other  certifying  officer and I are responsible for
          establishing  and maintaining  disclosure  controls and procedures (as
          defined in Exchange Act Rules  13a-15(e) and  15d-15(e))  and internal
          control  over  financial  reporting  (as defined in Exchange Act Rules
          13a-15(f) and 15d-15(f) for the registrant and have:

          a)   Designed such disclosure controls and procedures,  or caused such
               disclosure  controls and  procedures to be  designated  under our
               supervision,  to ensure that material information relating to the
               registrant,  including  its  consolidated  subsidiaries,  is made
               known to us by others within those entities,  particularly during
               the period in which this report is being prepared;

          b)   Designated  such internal  control over financial  reporting,  or
               caused such  internal  control  over  financial  reporting  to be
               designed under our supervision,  to provide reasonable  assurance
               regarding  the   reliability  of  financial   reporting  and  the
               preparation  of financial  statements  for  external  purposes in
               accordance with generally accepted accounting principles;

          c)   Evaluated  the  effectiveness  of  the  registrant's   disclosure
               controls  and   procedures  and  presented  in  this  report  our
               conclusions  about the  effectiveness of the disclosure  controls
               and  procedures,  as of the  end of the  period  covered  by this
               report based on such evaluation; and

          d)   Disclosed in this report any changes in the registrant's internal
               control  over  financial   reporting  that  occurred  during  the
               registrant's  most  recent  fiscal  quarter  that has  materially
               affected,  or is  reasonably  likely to  materially  affect,  the
               registrant's internal control over financial reporting; and

    5.    The registrant's other certifying officer and I have disclosed,  based
          on our most recent  evaluation  of  internal  control  over  financial
          reporting,  to the  registrant's  auditors and the audit  committee of
          registrant's board of directors:

          a)   All  significant  deficiencies  and  material  weaknesses  in the
               design or operation of internal control over financial  reporting
               which are reasonably  likely to adversely affect the registrant's
               ability  to  record,  process,  summarize  and  report  financial
               information; and

          b)   Any fraud,  whether or not material,  that involves management or
               other employees who have a significant  role in the  registrant's
               internal control over financial reporting.


Date: December 7, 2004                       /s/ Jerry A. Shore
                                            ---------------------------------
                                            Jerry A. Shore
                                            Executive Vice President and
                                            Chief Financial Officer





                                                                      Exhibit 32

      CERTIFICATION OF CHIEF EXECUTIVE OFFICER AND CHIEF FINANCIAL OFFICER
                   PURSUANT TO SECTION 18 U.S.C. SECTION 1350

In connection  with this quarterly  report on Form 10-Q of Fred's,  Inc. each of
the  undersigned,  Michael J. Hayes and Jerry A. Shore,  certifies,  pursuant to
Section 18 U.S.C. Section 1350, that:

     1.   The report fully  complies with the  requirements  of Section 13(a) or
          15(d) of the Securities Exchange Act of 1934; and

     2.   The  information  contained  in this report  fairly  presents,  in all
          material respects,  the financial  condition and results of operations
          of Fred's, Inc.

Date: December 7, 2004                         /s/ Michael J. Hayes
                                              --------------------------------
                                              Michael J. Hayes
                                              Chief Executive Officer

                                               /s/ Jerry A. Shore
                                              --------------------------------
                                              Jerry A Shore
                                              Executive Vice President and
                                              Chief Financial Officer