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[letterhead]
LUTIN & COMPANY
575 Madison Avenue
New York, New York 10022
Telephone (212) 605-0335
Facsimile (212) 605-0325
February 13,
2004
By telecopier: 323-965-3816
Mr. Andrew Petillon
Branch Chief, Office of Enforcement
Pacific Regional Office
United States Securities and Exchange Commission
5670 Wilshire Boulevard, 11th Floor
Los Angeles, California 90036-3648
Re: Farmer Bros.
Co.
Dear Mr. Petillon:
Understanding that my January 8, 2004 letter concerning Farmer
Bros. Co. (the “Company”) has been referred to you for consideration, I am
sending you the accompanying copy of a “Petition” filed earlier today in the
Superior Court of California, County of Los Angeles, which is relevant to
the issues addressed in that letter.
You will see that the Petition seeks court enforcement of the
Company’s obligation – acknowledged by the Company – to provide records.
These records are needed to obtain information which the Company has been
repeatedly asked to report publicly, and which (a) would be required in the
reports of an investment company under the Investment Company Act of 1940
and (b) relates to matters being presented for shareholder voting at an
annual meeting now scheduled for February 23, 2004.
As a practical matter, though, nothing the court can do will get
the required information to shareholders before they must submit their votes
for a meeting to be held five business days from today. I therefore ask you
to consider acting to require the Company’s postponement of its meeting
until shareholders have been provided with the necessary information and had
a reasonable opportunity to consider it.
Please let me know if you have any questions about the history
of these information requests or their relevance to investor interests.
Sincerely,
Gary Lutin
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