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Re: Lakewood Golf & Country Club, Inc.

SEC-CFD Order No. 018-08 • Securities and Exchange Commission Departments • Corporate Governance and Finance Department (CGFD) • Feb 7, 2008

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February 7, 2008 SEC-CFD ORDER NO. 018-08 IN RE: LAKEWOOD GOLF & COUNTRY CLUB, INC. ORDER OF SUSPENSION Before this Commission is the continuing failure of LAKEWOOD GOLF & COUNTRY CLUB, INC. to comply with the disclosure requirements of SEC Form 12-1 in relation to Annex "C" of SRC Rule 12 and SRC Rule 68, as amended, with regard to its Amended Registration Statement which was filed with the Commission on June 5, 2006, despite due notice and hearing and extensions of time given. The Commission, therefore, in its meeting held last January 31, 2008, resolved to suspend the Company's registration statement and Certificate of Permit to Sell Securities to the Public. In view of the foregoing, the registration of securities and Certificate of Permit to Sell Securities to the Public issued in favor of LAKEWOOD GOLF & COUNTRY CLUB, INC. is hereby SUSPENDED for a period of sixty (60) days, or until it is able to submit its duly accomplished Amended Registration Statement together with the required exhibits as enumerated in our June 20, 2006 comment letter. CcSEIH Failure of the company to comply with the foregoing Order within the specified period shall constrain the Commission to initiate proceedings for the revocation of the company's registration of securities, which will entail the return of any and all payments received from purchasers of its securities within ten (10) days from publication of the notice of revocation by the Commission, in accordance with SRC Rule 13.1. SO ORDERED. February 7, 2008, Mandaluyong City. For the Commission: (SGD.) JUSTINA F. CALLANGAN Director

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