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February 11, 1999
FEDERAL EXPRESS
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. William L. Tolbert, Jr.
Mr. Harry S. Pangas
Re: CASULL ARMS CORPORATION (THE "COMPANY")
WITHDRAWAL OF FORM SB-2
FILED ON NOVEMBER 27, 1996
FILE NO. 333-16911
Dear Ladies and Gentlemen:
Please be advised that on behalf of the Company, we hereby request
that the above referenced Form SB-2 be withdrawn pursuant to the provisions
of Rule 477 of the rules and regulations under the Securities Act of 1933.
Please call the undersigned at (212) 830-5778 if you have any
comments or if we can furnish any additional information or otherwise be of
assistance.
Very truly yours,
/s/ Willie E. Dennis
Willie E. Dennis