EXHIBIT 5.1

                       [Letterhead of The Otto Law Group]

                                 August 3, 2004

ACS Holdings, Inc.
7658 Municipal Drive
Orlando, Florida 32819


Ladies and Gentlemen:

         In connection with the registration on Form S-8 under the Securities
Act of 1933, as amended, of an aggregate of 165,000,000 shares of common stock
(the "Shares") to be issued pursuant to a Consulting Services Agreement dated
February 12, 2004, by and between ACS and Bartholomew International Investments
Ltd., Inc., as amended on April 22, 2004, May 19, 2004, June 1, 2004, July 12,
2004, July 26, 2004, and August 3, 2004 (the "Bartholomew Agreement"), we have
examined such documents and have reviewed such questions of law as we have
considered necessary and appropriate for the purposes of this opinion and, based
thereon, we advise you that, in our opinion, when the Shares have been issued
and sold pursuant to the applicable provisions of the Bartholomew Agreement and
in accordance the Form S-8, the Shares will be validly issued, fully paid and
nonassessable shares of the Company's common stock.

         We hereby consent to the filing of this opinion as an exhibit to the
above-described registration statement.

                                                     Very truly yours,

                                                     THE OTTO LAW GROUP, PLLC

                                                     /s/ The Otto Law Group