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Management Argument to Exclude Shareholder Proposal for Restoring Cumulative Voting (September 12, 2003) Representing the management of Farmer Bros. Co., Joseph J. Giunta of Skadden Arps Slate Meagher & Flom LLP submitted a September 12, 2003 to the Securities and Exchange Commission ("SEC") arguing that the company should not be required to present shareholders with a proposal of Mitchell Partners, L.P., for the restoration of cumulative voting. The letter seeks SEC concurrence with management's position that the shareholder proposal may be excluded from the company's proxy statement pursuant to Rule 14a-8 because, in the attorney's opinion, the proposed amendment to the company's Bylaws would be inconsistent with the California Corporations Code. Copies of the letter and its referenced exhibits can be accessed from the links below. Mitchell Partners is expected to submit a reply letter* to the SEC for its consideration. The SEC staff normally responds to such "no action" requests within six weeks. ______________ * Mitchell Partners submitted a reply letter on October 3, 2003.
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