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Strategic Timber Trust, Inc.
5 North Pleasant Street
New London, NH 03257
Telephone: 603.526.7800
Fax: 603.526.7811
July 13, 1999
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: Withdrawal of Strategic Timber Trust, Inc. Registration
Statement on Form S-11 (File No. 333-71291) and Registration
Statement on Form 8-A (File No. 000-25819)
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended (the
"Securities Act"), Strategic Timber Trust, Inc. hereby requests that its
Registration Statement on Form S-11 (File No. 333-71291), as amended, be
withdrawn from registration under the Securities Act. Strategic Timber requests
withdrawal of the Registration Statement because it has been advised by its
underwriters that current market conditions are not conducive to an initial
public offering of common stock by Strategic Timber. No shares of common stock
have been issued or sold under the Registration Statement.
We supplementally request withdrawal of Strategic Timber's Registration
Statement on Form 8-A (File No. 000-25819), which was filed on April 20, 1999
under the Securities Exchange Act of 1934, as amended, in connection with the
withdrawal of the above-referenced Securities Act registration statement.
Very truly yours,
/s/ Thomas P. Broom
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Thomas P. Broom,
Executive Vice President
