-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, MAApi/7Ca/wUr6COsJrTgczVkLZKEfWh7Ytl8dHVW5VmZO3DesbuXhJZmuHxe0kU aFlo+HXxnN3Yp52LlvR2QQ== 0000921895-06-001046.txt : 20061102 0000921895-06-001046.hdr.sgml : 20061102 20060501181342 ACCESSION NUMBER: 0000921895-06-001046 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060501 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ACCIPITER CAPITAL MANAGEMENT, LLC CENTRAL INDEX KEY: 0001280190 IRS NUMBER: 134220800 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 399 PARK AVENUE STREET 2: 38TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 BUSINESS PHONE: 2127058700 MAIL ADDRESS: STREET 1: 399 PARK AVENUE STREET 2: 38TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 FORMER COMPANY: FORMER CONFORMED NAME: ACCIPITER CAPITAL MANAGEMENT DATE OF NAME CHANGE: 20040213 CORRESP 1 filename1.htm sec document

OLSHAN
OLSHAN GRUNDMAN FROME ROSENZWEIG & WOLOSKY LLP

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                         May 1, 2006                     FACSIMILE: 212.451.2222

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                                                   EMAIL: SWOLOSKY@OLSHANLAW.COM


BY FACSIMILE AND FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mara L. Ransom


                  Re:      LifePoint Hospitals, Inc.
                           PRRN14A filed on April 20, 2006
                           DFAN14A filed on April 21, 2006
                           Filed by Accipiter Life Sciences Fund, LP et al.
                           File No. 0-51251

Dear Ms. Ransom:

         We  acknowledge  receipt of the letter of comment  dated April 24, 2006
from the Staff  (the  "Comment  Letter")  with  regard  to the  above-referenced
matter.  We have reviewed the Comment  Letter with Accipiter Life Sciences Fund,
LP ("Accipiter") and provide the following  supplemental response on its behalf.
Our responses are numbered to correspond to your comments.

SCHEDULE 14A

     1.  The Staff has asked Accipiter to provide support for the statement that
         the multiple for the  acquisition  of the HCA Hospitals is equal to 10x
         EBITDA.  During LifePoint's January 9, 2006 conference call, management
         estimated  that  EBITDA for the nine  months  they  expected to own the
         facilities would be $24 to $27 million, or $34 million  annualized.  In
         LifePoint's Form 10-Q for the second fiscal quarter of 2005,  LifePoint
         reported that the purchase price for the HCA Hospitals was $285 million
         plus $45 million of working capital,  or a total purchase price of $330
         million.  The quotient obtained by dividing $330 million by $34 million
         is 9.7x, or  approximately  10x EBITDA.  See attached support for these
         statements.


                                                               NEW JERSEY OFFICE
                                                       2001 ROUTE 46 / SUITE 202
                                                    PARSIPPANY, NEW JERSEY 07054
                                                         TELEPHONE: 973.335.7400
                                                         FACSIMILE: 973.335.8018




DEFINITIVE ADDITIONAL MATERIALS FILED ON APRIL 21, 2006

     2.  Accipiter  ensures  that  it  will  refrain  from  making  the  type of
         statements referred to in this comment in future communications.

     3.  See attached support for the peer group average as compared to
         LifePoint for executive compensation.

                                    * * * * *

         The Staff is invited to contact the  undersigned  with any  comments or
questions it may have.

                                 Very truly yours,


                                 /s/ Steven Wolosky
                                 ---------------------------
                                 Steven Wolosky

Enclosures

cc:      Gabe Hoffman


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