<PAGE>
Law Offices of
Paul, Hastings, Janofsky & Walker LLP
555 S. Flower Street, 23/rd/ Floor
Los Angeles, California 90071-2371
Telephone (213) 683-6000
Facsimile (213) 627-0705
Internet www.phjw.com
August 15, 2000
VIA EDGAR
---------
Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: The Pacific Capital Funds - CIK No. 896647
Request for Withdrawal of an Amendment to the Registration Statement
on Form N-14
File Nos. 333-35994 and 811-7454
Sir or Madam:
On behalf of Pacific Capital Funds (the "Registrant") and pursuant to
Rule 477(a) under the Securities Act of 1933, as amended (the "Securities Act"),
we hereby request the withdrawal of Post-Effective Amendment No. 1 (the
"Amendment") to the Registrant's Registration Statement on Form N-14 (the
"Registration Statement"), incorrectly filed with the Commission on July 14,
2000, as an N-14 Registration Statement. As requested by Commission staff, the
Amendment was correctly re-filed under Rule 485(b) on July 17, 2000.
Please address any comments or questions concerning this withdrawal
request to the undersigned at (213) 685-6207 or to William A. Crowfoot (213)
683-6312.
Very truly yours,
/s/ Michael Glazer
of PAUL, HASTINGS, JANOFSKY & WALKER LLP