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SEWARD & KISSEL LLP
1200 G Street, N.W.
Washington, D.C. 20005
Telephone (202) 737-8833
Facsimile: (202) 737-5184
October 15, 1999
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Ms. Gilheany
Valenzuela Capital Trust - CIK No. 1089344
Request for Withdrawal of Amendment to
Registration Statement on Form N-1A
Filed on October 14, 1999
(File Nos. 333-81561 and 811-09405)
Dear Ms. Gilheany:
On October 14, 1999 an amendment to the registration of
Valenzuela Capital Trust was inadvertantly filed as a pre-
effective amendment instead of as a post-effective amendment as
had been previously discussed with the staff. Subsequently on
October 14, the amendment was correctly filed as Post-effective
Amendment No. 1 pursuant to Rule 485(a). The accession number
for the erroneously designated amendment was 919574-99-1072.
On behalf of Valenzuela Capital Trust, we request,
pursuant to Rule 477(a) under the Securities Act of 1933,
withdrawal of the inadvertently filed "Pre-effective Amendment
No. 3," accession number 919574-99-1072.
We appreciate your assistance in this matter.
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Very truly yours,
/s/ Kathleen K. Clarke
Enclosures
52289006.AC3
