Flitways Technology Inc (FTWS)

[PennystockID2017]

______LAW OFFICE OF TIMOTHY P. THOMAS, LLC_____
1771 E. Flamingo Rd., Ste. 212-B FAX [phone]
Las Vegas, NV 89119 E-MAIL: [e-mail]
PHONE: [phone] WEB SITE: http://www.tthomaslaw.com
October 31, 2019
Island Stock Transfer
15500 Roosevelt Boulevard, Ste. 301
Clearwater, Florida 33760
SUBJECT: Security Shares
My office has been retained by FLITWAYS TECHNOLOGY, INC. (FTWS) with regard to the
debt conversion and issuance of 75,000,000 shares of common stock that is claims by EMA
FINANCIAL LLC (EMA),.
FTWS disputes the stock conversion sale on several points and asserts that this dispute must be
resolved prior to authorizing any issuance of these shares.
The asserted shareholder has claimed to have made payment to FTWS in July 2017, for the
purchase of the shares. FTWS does not have a record of the transaction or the receipt of funds
by FTWS. The alleged shareholder has provided a copy of an alleged bank statements of a
FTWS account. FTWS disputes that this statement is for a company account. The statement
reflects an apartment address in Los Angeles, California, that was not a corporate address. The
correct corporate address at that time was 400 Corporate Point, Ste. 300, Culver City, California.
FTWS has conducted an exhaustive search of its bank records to determine if such a payment
was received and no evidence of payment has been found. In August 2018, FTWS filed an 8K to
set forth prior managements inappropriate actions that are being investigated in connections with
the time of this alleged transaction.
The possession of such a bank statement by an investor, raises the issue of whether the investor
was an insider, issuer or investor of FTWS at the time and has insider information regarding the
issuance. The transaction in question is for the amount of $99,200, not the $110,000 stated in Mr.
Tal Tomer, esq.’s letter.
Additionally, the conversion rate does not appear to be correct. The note calls for a 30%
discount 3 day look back. However, Mr. Tomer reflects a conversion at approximately 0.000032
of the FTWS par value of 0.0001. The conversion rate would be 1300% discount. These
conversion rates would lead to a conclusion that the alleged shareholder would hold more than
5% of FTWS and has not registered as such on Form 13g.
This letter and the opinions herein are based solely upon the facts and assumptions set forth
herein and is specifically limited to the investigation and examination completed to date. After
this investigation I know of no facts which lead me to conclude that my opinion is not correct.
These above issues indicate that there may have been insider involvement and the need for
further investigation prior to authorizing the conversion of shares. FTWS therefore demands that
you refuse the request to convert the disputed debt note or at the very least in an abundance of
caution, deny the request to remove the restrictive legend on these shares.
Sincerely,
Timothy P. Thomas, Esq.