ETOTALSOURCE, INC.
                               1510 POOL BOULEVARD
                               YUBA CITY, CA 95993
                                 (530) 751-9015


April 19, 2005

VIA EDGAR

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

         RE:      ETOTALSOURCE, INC.
                  REGISTRATION STATEMENT ON FORM SB-2
                  FILED ON NOVEMBER 24, 2004
                  FILE NO. 333-120786

Ladies and Gentlemen:

         Pursuant to Rule 477(a) under the General Rules and Regulations under
the Securities Act of 1933, as amended (the "SECURITIES ACT"), please consider
this correspondence as an application to the United States Securities and
Exchange Commission (the "COMMISSION") for an order permitting eTotalSource,
Inc. (the "Registrant") to withdraw its Registration Statement on Form SB-2,
filed by the Registrant on November 24, 2004 (the "REGISTRATION STATEMENT").

         No securities were sold in connection with the Registration Statement.

         The Registrant further requests that all fees paid to the Commission in
connection with the filing of the Registration Statement be credited for future
use in accordance with Rule 457(p) of the Securities Act.

         Accordingly, the Registrant hereby respectfully requests that, in
accordance with the provisions of Rule 477(a) under the Securities Act, an Order
granting the withdrawal of the Registration Statement be issued by the
Commission as soon as reasonably possible.

         If you have any questions or comments regarding the foregoing
application for withdrawal, please contact Clayton E. Parker, Esq., legal
counsel to the Registrant, at 305-539-3300. Please provide a copy of the Order
consenting to this withdrawal to Mr. Parker by facsimile at 305-358-7095. Thank
you for your assistance.


                                            By:  /s/ Michael Sullinger
                                                -------------------------------
                                                     Michael Sullinger
                                                     Chief Operating Officer