AVVAA World Health Care Products : Annual Report 05/31/2022

Lloyd E. Ward, Esq.	Attorneys & Counselors at Law	Aden Vickers
[e-mail]	12801 North Central Expressway	[e-mail]
Website:	North Central Plaza III, Suite 460	Courtney Price, Paralegal
Dallas, Texas 75243
www.wardlegalus.com	Telephone: [phone]	[e-mail]
	Fax: [phone]

August 31, 2022

OTC MARKET GROUPS, INC.

300 Vesey Street, 12th Floor

New York, NY 10282

RE: AVVAA World Health Care Products, Inc. ("AVVH")

2022 Annual Disclosure

Dear Sir or Madam:

Ward Legal Group PLLC has acted as counsel to AVVAA World Health Care Products, Inc. ("AVVH" or the "Company") on certain securities and corporate issues, as instructed by the Company. This firm is domiciled in Texas, and I am licensed in Texas and Arkansas. All of our members, associates and employees are residents of the United States. Neither I nor any person associated with this firm owns any shares of the Company's securities, and neither I nor any person associated with this firm has ever received or has any agreement to receive the Company's stock in payment for services.

This firm was specifically tasked with reviewing the current information supplied by the Company to OTC Market Group, Inc. ("Market Group") for the year ended May 31, 2022; Market Group may rely upon this letter in determining whether the Company has made adequate current information publicly available, whether for purposes of SEC Rule 144(c) or its own internal regulations. Please note that the Company is and has been a "shell company" and is not an SEC-reportingentity, so that its shareholders are not currently

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eligible to rely on the "safe harbor" provisions of Rule 144; we provide these assurances for your benefit only.

The Company's current ownership and control structure results from a custodianship administered by a Clark County Nevada District Court in a proceeding conducted under provisions of Nevada Revised Statutes § 78.347. These provisions provide the custodian with significant authority over the operations of a corporation. We are not licensed or authorized to practice under Nevada law and provide no opinion as to the appointment or conduct of business by the custodian other than to note that all of the custodian's activities were directed or ratified by a court of competent jurisdiction.

The court filings appointing the custodian and the subsequent agreements describe the method by which the Company established and issued the 2021 Special Series A Convertible preferred share that constitutes the control block to the custodian, as well as the sale of such to Krisa Management, LLC and then to Omnis Public Capital Management LLC, a Texas limited liability company controlled by Miguel Sanchez, the Company's President, CEO and Chairman. We have also reviewed documents on-file with the Nevada Secretary of State, which confirmed the appointment of the custodian, reinstatement of the corporation, its subsequent actions in establishing the referenced preferred stock, and the appointment of Mr. Sanchez as an officer and director. The statements and representations in the Company's documents, the Court filings and orders, and the Nevada Secretary of State's records are all consistent with the representations in its 2022 Annual Report regarding the Company's history and control.

We have interviewed Mr. Sanchez and the Company's Treasurer, John Paul Garzon, by telephone. While neither of them has experience in public company reporting, both have significant experience in

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mortgage financing and originations, which is expected to be the Company's core business, and in general bookkeeping and accounting disciplines. Further, Carey Cooley, the principal of Krisa, who has significant experience in these matters, has agreed to provide administrative support for the Company's ARS postings and other public reporting. As augmented, the Company's management appears to have more than sufficient skills and experience to manage both its core business as well as its obligations to periodically provide material information to Market Group and the public.

Our review of the Company's current share ledger, which is maintained by its SEC-registered transfer agent, Signature Stock Transfer, Inc., reveals no shareholders with 5% or more of the Company's common shares, excepting CEDE & Co., which holds approximately 88% in the aggregate. In addition, the Company has issued 15,000,000 shares of its Series B Preferred Stock as of May 31, 2022, preliminary to concluding the acquisition of its core mortgage business; these shares are held by Gold Quest Capital, Inc., a Texas corporation controlled by Mr. Sanchez. These shares have no voting rights but are convertible at a rate of 100:1; there have been no conversions. We also noted that the Company timely posted a Change of Control addendum with Marketing Group following the acquisition.

.AVVH was an SEC-reporting issuer prior to filing a Form 15-12G on January 11, 2009; at that time, the Company had not filed its annual report on Form 10-KSB for the period ended May 31, 2008, and its last quarterly report on Form 10-QSB covered the period ended February 29, 2007. The SEC accepted the form 15-12G, however; and did not comment on several subsequent Forms 8-K. The Company is aware of the likely impact on future business that arise from missing or deficient filings, including impediments associated with reporting Other Corporate Events to FINRA. While almost certainly material, these matters do not affect our review of the current information required by OTC Market Group, Inc. for purposes of ARS postings.

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We have reviewed the annual report for the period ended May 31,2022, which was posted to OTC Disclosure News Service on August 29, 2022, and reports for previous periods, as well as the Attorney Letter provided for the period ended May 31, 2021. We have also reviewed additional corporate materials and legal filings, including documents concerning the appointment of the custodian, a subsequent change of control transaction, and a debt sale agreement. We have discussed the referenced information with current and past management and the Company's officers and directors.

To the best of our knowledge, after inquiry of management and a cursory internet search that included both the FINRA and SEC websites as well as WESTLAW, neither the Company, any officer, director, 5% holders of securities of the Company, nor corporate counsel are currently under investigation by any federal or state regulatory authority for any violation of federal or state securities laws. The Company has not received any request for information or other inquiry from FINRA and there is no record of any manner of regulatory inquiry.

The Company has announced it plans for effective a reverse merger with a mortgage origination and servicing business controlled by Mr. Sanchez, but none of these combinations had closed as of May 31, 2022. Our opinion covers only those matters that have been reported, and these appear accurate. Other than Mr. Sanchez' direct and indirect ownership, as reported, there are no other family relationships or related party transactions that require disclosure in AVVH's filings or in the Attorney Letter.

This letter was prepared in consideration and under the laws of the United States. We have not relied upon the opinion or representation of any other law firm. I am permitted to practice before the Securities and Exchange Commission without prohibition and have not, within the past five years, been the subject of an investigation, hearing, or proceeding by the SEC, CFTC, FINRA or any other federal, state, or foreign regulatory agency. I currently am subject to a probated suspension by the Texas Supreme Court due to a

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disciplinary matter that is unrelated to any securities law issues, but I am not currently or have been within the past five years, suspended or barred from practicing in any jurisdiction, nor have I been charged in a civil case by any government agency or any criminal case.

In rendering this letter, we have examined the following, all of which we believe is reliable:

1. Corporate records and other documents provided by the Company, to-wit: Financial documents including Balance Sheet, Statement of Operations, Statement of Cash Flows, Consolidated Statements of Stockholder's Deficiency (Statement of Changes in Shareholder Equity) and notes to the financial statements for the year ended May 31, 2022. The financial statements were prepared by Factsco, LLC, a Georgia based accounting and tax consulting firm; Factsco and its principal, Tyrus Young, provide similar services to several other smaller public companies. The financial statements are not audited and were prepared using documents prepared or provided by the Company; the financial statements are represented to have been prepared in accordance with GAAP. We have reviewed corporate documents including articles of incorporation and amendments, and the certificates of designation relating to the preferred stock, as well as purchase and sale agreements covering the change of control and ownership.
2. Information obtained on-line from the Secretary of State for Nevada and from a global WESTLAW search for litigation, judgments and other references.
3. Representations made to us by Mr. Cooley and Mr. Sanchez.
4. The shareholders' list provided by the Company's transfer agent, Signature Stock Transfer, Inc., Addison, Texas, a transfer agent registered with Securities and Exchange Commission.
   Based upon the foregoing and subject to the qualifications hereinafter set forth, we are of the opinion that the Company Information and Disclosure Statements for the period ending May 31, 2022, as submitted on August 29, 2021: