Silverton Adventures : Attorney Letter amended to include Attorney Agreement

ATTORNEY LETTER AGREEMENT

THIS AGREEMENT, dated as of the date executed by OTC Markets Group Inc. ("OTC Markets Group"), a Delaware corporation with an office located at 300 Vesey Street, 12th Floor, New York, NY 10282, is by and between OTC Markets Group and the ATTORNEY identified below (the "Attorney").

W I T N E S S E T H:

WHEREAS, OTC Markets Group operates the OTC Disclosure & News Service, a secure Internet portal for use by issuers to publish news releases, financial reports and other disclosures on www.otcmarkets.com;

WHEREAS, Attorney desires to prepare, or assist in the preparation of, information that is posted on the OTC Disclosure & News Service by, or on behalf of, the Issuer named below (the "Issuer"); and,

WHEREAS, prior to posting disclosure materials on the OTC Disclosure & News Service, and from time to time thereafter, OTC Markets Group requires the Attorney to prepare and submit a letter (each, a "Letter" and collectively, the "Letters") that conforms to the Attorney Letter Guidelines, attached hereto as Exhibit A and, in the case of securities that have been the subject of promotional activities, Exhibit B (collectively, the "Guidelines").

NOW THEREFORE, in consideration of the premises herein contained and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows:

Section 1. Attorney hereby consents to the posting of a Letter prepared by the Attorney by or on behalf of the Issuer from time to time through the OTC Disclosure & News Service, and OTC Markets Group hereby agrees to consider permitting any such Letter to be or remain posted through the OTC Disclosure

• News Service. Attorney represents that there are no legal or regulatory restrictions of any kind that would prohibit any such posting. Attorney will promptly notify OTC Markets Group in the event that Attorney ceases for any reason to provide services for the Issuer that would call for the preparation of a Letter in connection with information published by the Issuer through the OTC Disclosure & News Service.

Section 2. Attorney has attached to this Agreement a copy of the Attorney's driver's license for identification purposes.

Section 3. Attorney warrants and represents that (i) the document review and other duties required by the Guidelines have been competently performed in connection with the preparation of each Letter posted through the OTC Disclosure & News Service and (ii) each Letter conforms to the Guidelines.

Section 4. Attorney acknowledges and agrees that OTC Markets Group (i) in its sole, unfettered and absolute discretion, may fail or refuse to accept any Letter, and may determine that it will not accept any Letters that may be submitted in the future by the Attorney on behalf of the Issuer or any other company, for any reason whatsoever, (ii) is hereby granted full and complete permission, rights and authority to publish the reasons for any such failure, refusal or determination, and Attorney hereby represents and warrants that there are no legal or regulatory restrictions of any kind that would restrict or prohibit any such

publication, and (iii) shall not be liable to counsel for any damages whatsoever, whether the theory of liability is based on contract, tort or otherwise, (x) that are related in any way to any such failure, refusal or determination or (y) in connection with any publication by OTC Markets Group of the reasons for any such failure, refusal or determination.

IN WITNESS WHEREOF, the parties hereto have caused this agreement to be executed by their duly authorized officers.

The Attorney

McLaughlin & Stern, LLP

Name of Firm

Address:

260 Madison Avenue, New York, NY 10016

Phone Number: [phone]

Email: [e-mail]

By (signature): /s/Steven W. Schuster

Name of Attorney (print): _ Steven W. Schuster

Title: Partner

Issuer Name: Silverton Adventures, Inc.

Trading Symbol: SVAD

OTC Markets Group Inc.

By:

Gareth Colglazier

Signed for Liz Heese, EVP, Issuer Services

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Attorney Letter Agreement

Version 3.1 December 2019

July 29, 2022

OTC Markets Group, Inc.

300 Vesey Street, 12th Floor

New York, NY 10282

Re: Attorney Letter with Respect to Adequate Current Information, Continuing Disclosure Obligations of Silverton Adventures, Inc., a North Carolina Corporation (the "Issuer") for the annual report, as amended, and period ending June 30, 2022, and quarterly reports for the periods ending March 31, 2022 and December 31, 2021.

To Whom It May Concern:

This firm has been engaged by Silverton Adventures, Inc., a North Carolina Corporation (the "Issuer"), as general counsel, including, but not limited to, for the purpose of rendering this letter and related matters.

This letter may be posted on the OTC Disclosure and News Service for viewing by the general public. OTC Markets Group, Inc. ("OTC") may rely on this opinion in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) of the Securities Act of 1933, as amended (the "Securities Act").

The undersigned counsel ("Counsel") is licensed in the State of New York and is a resident of the State of New York. He subject matter of this letter covers the jurisdiction of the State of North Carolina (the Issuer's state of incorporation) and the laws of the United States. Counsel is permitted to practice before the Securities Exchange Commission ("SEC") and has not been prohibited from practice thereunder. Counsel has not ever been suspended or barred from practicing law in the State of New York or in any other jurisdiction, nor has Counsel ever been charged in any civil or criminal case or been the subject of an investigation, hearing, or proceeding by the SEC, the US Commodity Futures Trading Commission, FINRA, or any other federal, state or foreign regulatory agency. Counsel is current in his membership requirements for the State of New York. Counsel does not beneficially own any shares of Issuer's common stock, nor does Counsel have any current agreements to receive, whether now or in the future, shares of Issuer common stock as compensation for preparation of this letter or for any other services.

This firm has been retained by the Issuer for the purpose of reviewing the current information supplied by the Issuer and has been retained as outside counsel for other matters. Counsel has examined such corporate

{Attorney's Letter dated 7.22.2022 re Annual Report FYE 6.30.2022 v3 (Clean).1}

records and other documents and such questions of law as Counsel considered necessary or appropriate for the purposes of rendering this letter.

For purposes of this opinion Counsel has reviewed the following:

1. Articles of Incorporation and Amendments of the Articles of Incorporation of the Issuer;
2. Corporate By-Laws;
3. Information, as defined below; and,
4. Such other corporate records as were necessary and provided by management for purposes of this letter, including press releases and past and current financial statements have examined such corporate records and other documents and such questions of law as Counsel considered necessary or appropriate for purposes of rendering this letter.

The opinion and conclusions herein are based upon documentation and facts made available by the Issuer and are based on the presumed accuracy of those documents and facts. Al such information is believed to be true and such sources of information are believed to be reliable. As to matters of fact, Counsel relied on information obtained from public officials, officers of the Issuer and other sources, and believed such information to be true and such sources of information are believed to be reliable. If the facts and information in all such documents are determined not to be true, this opinion shall be null and void.

The Issuer posted on t he OTC Disclosure and News Service the following report (hereinafter collectively "Information"):

Publish		Report Title	Period End
Date			Date
July 26,	Amended Annual Report - For the Year ended June 30, 2022, which	June 30, 2022
2022	included the following unaudited Financial Statements:
	•	Balance Sheet
	•	Statement of Operations
	• Statement of Stockholder's Equity
	•	Statement of Cashflows
	• Notes to Financial Statements
May 11,	Quarterly Report - For the Period ended March 31, 2022, which included the	March 31,
2022	following unaudited Financial Statements:	2022
	•	Balance Sheet
	•	Statement of Operations
	• Statement of Stockholder's Equity
	•	Statement of Cashflows
	• Notes to Financial Statements
January 31,	Quarterly Report - For the Period ended December 31, 2021, which included	December 31,
2022	the following unaudited Financial Statements:	2021
	•	Balance Sheet
	•	Statement of Operations
	• Statement of Stockholder's Equity
	•	Statement of Cashflows
	• Notes to Financial Statements

Counsel is of the belief and opinion the Information (i) constitutes "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. (ii) includes all of the information that a broker-dealer would be required to obtain

{Attorney's Letter dated 7.22.2022 re Annual Report FYE 6.30.2022 v3 (Clean).1}

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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 Group's Pink Basic Disclosure Guidelines, which are located on the Internet at www.otcmarkets.com, and (iv) has been posted on the OTC Disclosure and News Service.

The financial statements contained in the Information above are unaudited and were prepared by the sole director and officer of the Issuer, Heung Kwok David Mui, who has over 30 years' experience in corporate finance and business administration and possess a Master of Business Administration.

The transfer agent for the Issuer is:

Pacific Stock Transfer Company 6725 Via Austin Parkway, Suite 300 Las Vegas, NV 89119

[phone]

The Transfer Agent is listed with the Commission and has Depository Trust Corporation approval. For the relevant period, the Issuer had the following number of shares of Common Stock issued and outstanding:

Period End Date	Shares Issued & Outstanding
June 30, 2022	10,057,491,143
March 31, 2022	7,807,491,143
December 31, 2021	7,807,491,143

Counsel confirmed these figures by reviewing records issued by the Transfer Agent.

The corporate offices of the issuer are located at Room 1302, 13/F, Billion Trade Centre, 31 Hung To Road, Ngau Tau Kok, Kowloon, Hong Kong and its phone number is [phone].

The Issuer was originally incorporated in 2006 under the laws of the state of Nevada as Mor Travel, Inc. In December of 2007, the Issuer's name was changed to Silverton Adventures, Inc. In 2014, the Issuer redomiciled to the state of Wyoming. From inception until through 2014, the Issuer provided through its subsidiaries, printing and mailing services in addition to children's DVDs and programs. The issuer has not reported any operations since September 30, 2014. In February 2019, the issuer's jurisdiction of incorporation changed from Wyoming to North Carolina. The company is preparing to remarket themselves and may move into a new direction with respect to its principal products or services.

Pursuant to the Issuer's unaudited financial statements filed with its Annual Report, the Issuer's reported assets and revenues were as follows:

Period End Date	Assets			Revenues
June 30, 2022	$	0	$	0
March 31, 2022	$	0	$	0
December 31, 2021	$	0	$	0

Counsel has reviewed the Information in conjunction with its preparation of this letter and finds the Information suitable and ready for public disclosure. Counsel has also personally met and discussed the Information provided to OTC Disclosure and News Service via conference call with Heung Kwok David Mui, the Issuer's sole officer and director as of the date of this opinion.

{Attorney's Letter dated 7.22.2022 re Annual Report FYE 6.30.2022 v3 (Clean).1}

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