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PEMCO AVIATION GROUP, INC.
1943 NORTH 50TH STREET
BIRMINGHAM, ALABAMA 35212
June 27, 2000
VIA FACSIMILE AND EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Alfred Barbagallo
Re: Pemco Aviation Group, Inc.
Form RW - Application for Withdrawal
File No. 333-35920
Ladies and Gentlemen:
Pursuant to Rule 477(a) of Regulation C of the General Rules and
Regulations under the Securities Act of 1933, as amended, the undersigned, on
behalf of Pemco Aviation Group, Inc., formerly known as Precision Standard, Inc.
(the "Registrant"), respectfully requests an order granting the immediate
withdrawal of its registration statement on Form S-3, File No. 333-35920,
together with all exhibits thereto (the "Registration Statement"). The
Registration Statement was filed with the Securities and Exchange Commission on
April 28, 2000.
Pursuant to the Registration Statement, the Registrant proposed
to register shares of its Common Stock, par value $0.0001 (the "Shares"), for
sale by the selling stockholders described in the Registration Statement. The
Shares were pledged to the selling stockholders in connection with the
settlement of claims against the Registrant. In the event the Registrant
defaulted on its payment obligations under the terms of the settlement, the
selling stockholders would have been entitled to sell the Shares to make up any
deficiency.
The Registrant has now satisfied its payment obligations under
the terms of the settlement, thus extinguishing the selling stockholders' right
to sell the Shares. Accordingly, the Registrant hereby requests that an order
granting the withdrawal of the Registration Statement be issued by the
Securities and Exchange Commission as soon as possible.
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Should you have any questions concerning this matter, please do
not hesitate to contact Craig M. Garner, Esq. of Latham & Watkins, legal counsel
to the Registrant, at (619) 236-1234. Thank you for your assistance and
cooperation in this matter.
PEMCO AVIATION GROUP, INC.
By: /s/ Ronald A. Aramini
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Ronald Aramini
Chief Executive Officer and
President
