[LETTERHEAD OF COUNTRY WIDE TRANSPORT SERVICES, INC.]
Securities and Exchange Commission
450 Fifth Street
Washington, D.C. 20549
Re: Country Wide Transport Services, Inc
Application for Withdrawal of Registration Pursuant to Rule 477
Registration No. 333-31581
Dear Ladies and Gentlemen:
I am the President of Country Wide Transport Services, Inc. ("Registrant"
or the "Corporation"), and I am the designated agent for service of the
Registrant in the above specified Registration Statement. The Registrant hereby
applies for withdrawal of that Registration Statement.
On August 2, 1999, the Corporation completed the cash sale of
substantially all of its operating assets to C.H. Robinson Company in Eden
Prairie, Minnesota for cash. The closing of that sale was reported on the
Corporation's Form 8-K report filed on August 13, 1999. Pursuant to a Plan of
Liquidation and Dissolution approved by its stockholders, the Corporation is in
the process of liquidation. It recently paid a 60 cent per share liquidating
distribution and holds about 25 cents per share in reserve, which will be
available to pay housekeeping expenses and, if needed, contingent liabilities.
Since final resolution of those contingent liabilities is months away and
depends on unpredictable contingencies, any investment in the stock is highly
speculative and very little, if any, trading in the Corporation's stock is
anticipated. Under these circumstances maintenance of the S-2 Registration
Statements seems unwise to say the least. Each of the stockholders whose shares
are registered under the Registration Statement has consented to the requested
withdrawal.
To put this request in context, registration of the Shares in 1997 was
initiated solely to permit their resale by certain shareholders of the
Corporation. To-date, none of the Registered Shares has ever been sold under the
registration statement. Also, on September 24, 1999, the Corporation filed a
Form 15 to terminate its registration of the Corporation's Common Stock under
Section 12(g) of the Securities Exchange Act of 1934.
Accordingly, the Registrant respectfully requests that the Commission
consent to the withdrawal of the above-referenced Registration Statement as soon
as practicable.
Very truly yours,
/s/ Timothy Lepper
Timothy Lepper
President
