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PAUL, HASTINGS, JANOFSKY & WALKER LLP
555 South Flower Street
Los Angeles, California 90071
Telephone (213) 683-6000
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Elisa Metzger
Re: Nicholas-Applegate Series Trust
Rule 477 Filing
File Nos. 33-94896, 811-9074
CIK No. 0000948525
Ladies and Gentlemen:
Pursuant to our recent conversation with Elisa Metzger of the Commission
staff, this letter constitutes a request on behalf of our client
Nicholas-Applegate Series Trust (the "Trust"), pursuant to Rule 477 under the
Securities Act of 1933, for withdrawal of the Trust's pending registration
statement. The Trust has not commenced business or offered or sold any
securities, and does not intend to do so in the foreseeable future.
Please do not hesitate to contact me if you have any questions regarding
this request. Thank you for your assistance regarding this matter.
Very truly yours,
Michael Glazer
for PAUL, HASTINGS, JANOFSKY & WALKER LLP