<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>2
<FILENAME>ncvpwc.txt
<DESCRIPTION>INTERNAL CONTROL LETTER
<TEXT>



Report of Independent Accountants

To the Board of Trustees and Shareholders
of Nicholas-Applegate Convertible  Income Fund


In planning and performing our audit of the financial
statements of Nicholas Applegate Convertible  Income Fund
the Company for the year ended February 29, 2004, we
considered its internal control, including control activities for
safeguarding securities, in order to determine our auditing procedures
for the purpose of expressing our opinion on the financial statements
and to comply with the requirements of Form N SAR, not to
provide assurance on internal control.

The management of the Company is responsible for establishing and
maintaining internal control.  In fulfilling this responsibility, estimates
and judgments by management are required to assess the expected
benefits and related costs of controls.  Generally, controls that are
relevant to an audit pertain to the entitys objective of preparing
financial statements for external purposes that are fairly presented in
conformity with generally accepted accounting principles.  Those
controls include the safeguarding of assets against unauthorized
acquisition, use or disposition.

Because of inherent limitations in internal control, errors or fraud may
occur and not be detected.  Also, projection of any evaluation of
internal control to future periods is subject to the risk that controls
may become inadequate because of changes in conditions or that the
effectiveness of their design and operation may deteriorate.

Our consideration of internal control would not necessarily disclose
all matters in internal control that might be material weaknesses
under standards established by the American Institute of Certified
Public Accountants.  A material weakness is a condition in which
the design or operation of one or more of the internal control
components does not reduce to a relatively low level the risk that
misstatements caused by error or fraud in amounts that would be
material in relation to the financial statements being audited may
occur and not be detected within a timely period by employees
in the normal course of performing their assigned functions.
However, we noted no matters involving internal control and its
operation, including controls for safeguarding securities, that
we consider to be material weaknesses as defined above as of
February 29, 2004.

This report is intended solely for the information and use of the
Board of Trustees, management and the Securities and Exchange
Commission and is not intended to be and should not be used
by anyone other than these specified parties.

PricewaterhouseCoopers LLP
April 19, 2004

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</DOCUMENT>
