11/14/2003 1:00AM

A tad too long for 'Winter'?

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ETOBICOKE, Ontario - Winter Garden, the most accomplished 3-year-old filly sprinter in Canada, will seek her third consecutive win against older opponents Sunday at Woodbine in the $164,400 Bessarabian Handicap.

Winter Garden has had a lucrative campaign, winning 5 of 8 starts while banking $372,186. She won her first stakes April 5 in the six-furlong Star Shoot, and showed she could handle 1 1/16 miles when she finished third after a dead-rail trip in the Grade 1 Selene Stakes.

Winter Garden gamely held off the imposing One for Rose when she captured a seven-furlong allowance Sept. 21. She most recently won the six-furlong Ontario Fashion Handicap, receiving her second consecutive Beyer Figure of 94.

Trainer Bob Tiller said he believes Winter Garden has retained her sharpness heading into the Bessarabian. He said his main concern is the distance.

"She has to go seven-eighths - that's my big question mark," Tiller said. "She could beat any mare on the grounds going six or six and a half. She's a lovely filly, and she runs hard every time, but she's had a long campaign."

David Clark retains the mount on Winter Garden, whose second dam is 1987 Canadian champion 2-year-old filly Phoenix Factor.

Completing the lineup for the Grade 3 Bessarabian are Acting Deputy, Ginger Gold, Mille Feville, El Prado Essence, Whiletheiron'shot, and Sheila's Prospect.

Acting Deputy also won an early-season stakes, the La Voyageuse Handicap, and was third behind future Grade 1 winner Harmony Lodge and Winter Garden in the June 22 Sweet Briar Too Stakes. She won a six-furlong allowance when she returned from a layoff Oct. 5, and was recently fifth in the Fashion.

"She's had little problems here and there, and she ran hard until [the Sweet Briar Too]," said trainer Vito Armata. "She needed a little break, so I gave her the summer off, and she came back good."

Even though Acting Deputy won in the slop last fall, Armata said he probably won't run her on such a track Sunday. "She can't handle an off track," Armata said. "She doesn't like it deep."

Sheila's Prospect won the 2002 Bessarabian following a second-place finish in the Ontario Fashion, and is coming into this year's Bessarabian off a third-place finish in the Ontario Fashion. She's winless on the year, but trainer Lorne Richards should have her peaking in her third start off a layoff.

* Stakes winners Winter Whiskey and Twisted Wit head Sunday's supporting feature, the $106,000 Sunny's Halo Stakes, a 6 1/2-furlong sprint for Canadian-bred 2-year-olds.