LM Capital Investments Trust
120 South Olive
West Palm Beach, Florida 33401
January 7, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Withdrawal of Registration Statement on Form N-1A
by LM Capital Investments Trust Registration No. 33-91428
Ladies and Gentlemen:
LM Capital Investments Trust (the "Registrant"), hereby applies to the
Securities and Exchange Commission (the "Commission"), pursuant to Rule 477(a)
under the Securities Act of 1933, as amended (the "Securities Act"), to approve
the withdrawal of its initial Registration Statement on Form N-1A, Registration
No. 33-91428, filed on April 20, 1995 and three accompanying pre-effective
amendments thereto dated March 8, 1996, September 5, 1996 and December 24, 1997,
respectively (collectively, the "Registration Statement").
The Registration Statement was filed in connection with the
registration of shares of the Registrant offered through LM Capital Evolving
Venture Fund, an equity mutual fund (the "Fund"). However, the Registrant seeks
to pursue a different business direction and does not wish to continue offering
shares through the Fund. The Registrant has determined that the withdrawal of
the Registration Statement is consistent with the public interest and the
protection of investors.
The Registrant respectfully requests that this Application to withdraw
the Registration Statement be approved by the Commission as soon as possible.
If you have any questions with respect to this Application, please
contact Peter O'Rourke of Kramer Levin Naftalis & Frankel LLP, counsel to the
Registrant, at (212) 715-7509.
LM Capital Investments Trust
By: /s/ Leslie M. Corley
-------------------------------------
Leslie M. Corley
President
cc: Peter J. O'Rourke
