THE TURNER CORPORATION
375 HUDSON STREET
NEW YORK, NEW YORK 10014
April 8, 1999
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: The Turner Corporation
Registration Statement on Form S-3
(File No. 333-73351)
Ladies and Gentlemen:
Pursuant to Rule 477 of Regulation C of the Securities Act of 1933, as
amended, The Turner Corporation ("Registrant") hereby respectfully makes
application to the Securities and Exchange Commission (the "Commission")
for withdrawal of the above referenced Registration Statement, with such
application to be approved effective as of the date hereof or at the
earliest practical date thereafter. The Registration Statement was filed
through the Commission's Electronic Data Gathering, Analysis and Retrieval
system on March 4, 1999.
The Registration Statement was filed in connection with the proposed
sale of Registrant's Common Stock by two of Registrant's stockholders (the
"Selling Stockholders"). Each of the Selling Stockholders has requested
that the Registrant not complete at this time the registration of the
shares which had been proposed to be sold by it under the Registration
Statement and that the Registrant withdraw the Registration Statement. In
light of the Selling Stockholders' requests, management of the Registrant
believes that, since the purpose for which the Registration Statement was
originally filed has been eliminated, withdrawal of the Registration
Statement is appropriate. The Registrant confirms that no securities have
been issued or sold pursuant to the Registration Statement. The Registrant
understands that the filing fee for the Registration Statement will not be
returned to it.
<PAGE>
Please feel free to call the undersigned at (212) 229-6000 or Jeffrey
Bagner of Fried, Frank, Harris, Shriver & Jacobson at (212) 859-8136 if you
have any questions or comments.
Sincerely,
/s/ Sara J. Gozo
------------------
Sara J. Gozo
Vice President, Secretary and
General Counsel
cc: Jeffrey Bagner, Esq.
Fried, Frank, Harris, Shriver & Jacobson
