BlueFire Equipment : Attorney Letter Covering Disclosure Statements and Financial Statements for two full years and most recent three quarters

	DAVISSON & ASSOCIATES, PA
	ATTORNEYS AND COUNSELORS AT LAW
	3649 BRUNSWICK AVENUE NORTH
	MINNEAPOLIS, MINNESOTA 55422
	TELEPHONE [phone]
January 7, 2022
OTC Markets Group, Inc.	VIA PDF FOR FILING ON OTC MARKETS/PINK

304 Hudson Street -- 2nd Floor New York, New York 10013

Re: BlueFire Equipment Corporation - Attorney Letter with Respect to Current Information and Removal of Yield Sign having reviewed Initial Disclosure - Annual and Interim Disclosure Statements for Two Full Fiscal Years and the First, Second and Third Quarters and Two Full Years and the First, Second and Third Quarters of Financial Statements, (i.e for the Interim Periods ended March, 31, 2021, June 30, 2021 and September 30, 2021 and the Fiscal Years Ended December 31, 2019 and 2020).

Dear Sirs:

This letter is written on behalf of BlueFire Equipment Corporation, (the "Issuer"). OTC Markets Group, Inc. ("OTC Markets") is entitled to rely on such letter in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) under the Securities Act of 1933, as amended, with regard to Issuer's common stock (the "Securities"). This law firm Davisson & Associates, PA, is a professional corporation, incorporated in the State of Minnesota and the undersigned counsel (hereafter "Counsel") is a U.S. resident and they have been retained by the Issuer for the purpose of rendering this letter and related matters. We serve as corporate and securities counsel to the Issuer. Counsel has no relationship with the Issuer other than as attorney-client. Counsel does not now own any of the Issuer's Securities nor is there any agreement to receive shares in the future in payment for services or otherwise. Counsel has no existing or prior relationship with any prior counsel of Issuer.

Without relying on the work of other counsel, we have examined such corporate records and other documents and such questions of law as considered necessary or appropriate for purposes of rendering the letter and have relied on information obtained from public officials, the custodian, officers of the Issuer and other sources believed to be reliable. In connection with rendering this opinion, we have investigated such matters and examined such documents as deemed necessary. In examining the documents, we have assumed the genuineness of signatures (both manual and conformed), the authenticity of documents submitted as originals, the conformity with originals of all documents furnished as copies and the correctness of facts set forth in such documents.

Jason Lee Reid from Greystone Reporting, Ltd. assisted with preparation of the financial statements of the Issuer for current information and initial disclosure purposes, whose business and email addresses are respectively, 40 Wall Street 28th Floor, New York, NY 10005 and jason@greystone-reporting. Neither he nor Greystone holds any of the Issuer's shares of stock.

Counsel has made specific inquiry of each of the persons listed above, and persons owning more than five percent (5%) of the Securities (collectively, the "Insiders") and none appear to have been persons engaged in promotional activities regarding the Issuer as all hold only restricted shares and based upon such inquiries and other information available to counsel, no sales of the Securities by Insiders have been made within the twelve-month period prior to the opinion thus they are in compliance with Rule 144 "sales" requirements. Nothing has come to the attention of counsel indicating that any of the Insiders holding shares is in possession of any material non-public information

regarding the Issuer or the Securities that would prohibit any of them from buying or selling the Securities under Rules 10b-5 or 10b5-1 under the Exchange Act.

Counsel is authorized to practice law in the state of Minnesota and is permitted to practice before the U.S. Securities and Exchange Commission (the "Commission"), has not been prohibited from practice before the Commission, is not currently nor in the past five years, been- under investigation, been the subject of a hearing or proceeding by the Commission, by the U.S. Commodity Futures Trading Commission, by the Financial Industry Regulatory Authority or by any federal, state or foreign regulatory authority.

Counsel is not currently nor at any time in the past five years, been charged civilly or criminally, nor has Counsel been suspended or barred from practice in any jurisdiction for any such matter.

In connection with the preparation of this letter, we have reviewed the following documents in connection with the preparation of the letter (the "Information"), the dates that such documents were posted on OTC Disclosure and News Service ("OTC News Service" and formerly "Pink Sheets News Service") as well as Edgar as reflected therein:

Issuer was incorporated in Delaware on June 10, 2008 under the name BlueFire Equipment Corporation, on September 27, 2021 it changed domiciles via "conversion" to a Colorado Corporation under the same name and is in good standing. Issuer has undertaken to provide the most up-to-date information and has submitted the following documents to enable placement on OTC News Service (formerly Pink Sheets News Service) as current information through full corporate public disclosure, including its most recent Quarterly Report for the quarter ending September 30, 2021, the Annual Reports for years ending December 31, 2019 and December 31, 2020 along with the full financial statements, together with notes thereto, for the Quarters Ended March 31, 2021, June 30, 2021 and September 30, 2021 and the Fiscal Years Ending December 31, 2019 and December 31, 2020. This Information includes information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the Securities under Rule 15c2-11 and complies as to form with the OTC Markets Guidelines for Providing Adequate Current Information. This Information has been made available and verified by the appropriate officers and has been made available through the OTC Markets disclosure platform and includes not less than the following:

The following Information and documents were reviewed in relation to the Issuer:

All material contracts associated with Issuer;

Articles of incorporation and Corporate By-Laws;

Posted	Report Title	Period End Dates
September 27, 2021	Initial Disclosure Stmt for Fiscal	Dec 31, 2019
	Year Ending 2019 and Financial
	Statements
November 15, 2021	Initial Disclosure Stmt for Fiscal	Dec 31, 2020
	Year Ending 2020
September 27, 2021	Financial Statements for Fiscal	Dec 31, 2020
	Year Ending 2020
November 15, 2021	Initial Disclosure for First Quarter	March 31, 2021
	of 2021
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November 15, 2021	Financial Statements for First	March 31, 2021
	Quarter of 2021
November 15, 2021	Initial Disclosure Stmt for Second	June 30, 2021
	Quarter of 2021
September 27, 2021	Financial Statements for Second	June 30, 2021
	Quarter of 2021
January 7, 2022	Initial Disclosure Stmt for Third	September 30, 2021
	Quarter of 2021
January 7, 2022	Financial Statements for Third	September 30, 2021
	Quarter of 2021

The Disclosure Statements cover the two most recent fiscal years ending December 31, 2019 and 2020, the quarters ended March 31, 2021, June 30, 2021 and September 30, 2021, together with the two most recent years of financial statements for the years ended December 31, 2019 and 2020, the quarters ending March 31, 2021, June 30, 2021, and September 30, 2021, presented in accordance with US GAAP for these two years and quarters and Initial Disclosure Statements / Annual Reports for the two most recent fiscal years, Initial Disclosure Statements / Quarterly Report for the most recent quarters ended for the period covered at the initial submission of current information. The information, as of the periods covered by this letter, in our opinion, having so reviewed the above enumerated documents at the time of initial submission of and corrected, (i) constituted "adequate current public information" concerning the Securities and the Issuer and "is available" within the meaning of Rule 144(c)(2) under the Securities Act, including its dissemination on OTC Markets' disclosure platform; (ii) includes all of the substantive information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the Securities under Rule 15c2-11 under the Securities Exchange Act of 1934 (the "Exchange Act"); (iii) complies as to form with the OTC Markets Guidelines for Providing Adequate Current Information (v3 dated February 2021) which are located on the Internet at www.otcmarkets.com; and (iv) has been posted on the OTC Markets News Service.

Please be advised that:

• The person responsible for the preparation of the financial statements contained in the annual reports that are included in the Issuer's Disclosure Statement is Jason Lee Reid of Greystone Reporting, Ltd. whose address is 40 Wall Street 28th Floor, New York, NY 10005, Email jason@greystone-reporting, Telephone Number (347)-708-0410. The financial statements have not been audited. Mr. Reid has more than 20 years of experience as an accountant and many years of experience specifically assisting companies become US GAAP compliant. This was the primary purpose for which the Issuer engaged him; that is to assist the Issuer with the preparation of its financial statements and the notes thereto for filing with OTC Markets. Mr. Reid has confirmed that, while unaudited, all information for these December 31, 2019 and December 31, 2020 annual reports and the March 31, 2021, June 30, 2021 and September 30, 2021 quarterly reports have been provided, to the best of his ability, in accordance with GAAP standards, fairly representing in his view the financial position of the company.

• The Issuer's transfer agent is Issuer Direct Corporation, PO Box 1195 Greenboro, NC 27402; Telephone Number: (919)-481-4000, Email [e-mail] (the "Transfer Agent"). The Transfer Agent is registered under the Exchange Act. Counsel has confirmed that it is registered with the SEC.

• Counsel has, for the period covered by this report, (i) personally met with the board of directors Ali Ahmed and Ahmed Hassan via video conference and as of the date of this Information and as such, the requirement that counsel "personally meet with a majority of the board of directors" is met, (ii) reviewed

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the Information, as amended, published by the Issuer on the OTC Disclosure and News Service and (iii) discussed the Information with the board of directors.

• To the best of our knowledge, after inquiry, neither the issuer nor any holder of 5% of the Issuer's Securities, is currently under investigation by any federal or state regulatory authority for any violation of federal or state securities laws.
• The Issuer was previously considered a "shell company" as defined in Rules 405 of the Securities Act of 1933, as amended and Rule 12-b-2 of the Securities Exchange Act of 1934, as amended. The Issuer is now considered a shell company.

No person other than OTC Markets is entitled to rely on this letter but grants OTC Markets full and complete permission and rights to publish the letter in its OTC Markets Disclosure and News Service for viewing by the public and regulators. We are admitted to practice in the State of Minnesota, and the foregoing opinions are limited to the laws of said state and the federal laws of the United States of America. We express no opinion as to the applicability to or compliance with any state securities or "blue-sky" laws. In addition, this letter is given as of the date set forth above and is restricted to the stated facts and circumstances presented to us and described herein, and that any other or different facts and circumstances might require a different letter, and we assume no, and hereby disclaim any, obligation to update or supplement this letter to reflect any facts or circumstances that may hereafter come to our attention or any changes in laws that may hereafter occur or which occurred prior to the date hereof, the occurrence of which we had no knowledge.

Regards,

Davisson & Associates, PA

_______________________

By: Peder K. Davisson, Esq.

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