THE MANUFACTURERS LIFE INSURANCE COMPANY (U.S.A.)
                            38500 WOODWARD AVENUE
                       BLOOMFIELD HILLS, MICHIGAN 48304


December 17, 2002

VIA EDGAR

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington,  D.C.   20549



RE:    Rule 477(a) Filing - Application for Withdrawal of Registration Statement

       SEC Registration No. 333-101885, Filed on Form S-6

Dear Sir or Madam:

This Application for Withdrawal of Registration Statement is made in accordance
with Rule 477(a) under the Securities Act of 1933. Manufacturers Life Ins
Co USA Separate Account N respectfully requests the withdrawal of the
Form S-6 Registration No. 333-101885, filed on December 16, 2002.

The Form S-6 filing assigned Registration No. 333-101885 was filed in error. The
material included in the filing, which was submitted and accepted via EDGAR on
December 16, 2002, was intended as a Pre-Effective amendment filing to
Registration No. 333-100567. After the error was discovered, we made the correct
Form S-6/A filing for Registration No. 333-100567 on December 17, 2002. As
required by Rule 477(c), no securities were sold in connection with the filing
of Registration No. 333-101885.

We believe the withdrawal of Registration No. 333-101885 is in the public
interest and request the Commission's consent to this Application.

Sincerely,

/s/ Betsy Anne Seel
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Name: Betsy Anne Seel
Title: Senior Counsel