Well it is interesting but I can tell you that isnt the process of removing a chill. Further I can tell you that they are in fact a shell and that opinion letter isnt going to go very far with exception to a trash can. The only way to cure shell status is by becoming an SEC Filer, that shell has never registered, it has never filed once. The SEC requires reporting of a minimum of one year to cure the shell status of a company along with meeting the requirements of SEC Rule 144.
By the way that attorney is an idiot, doesnt have a clue about securities let alone securities law.