AVALON FUNDS INC
485APOS, EX-99.23.J, 2001-01-12
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                                   Exhibit 23I

                           DAVID JONES & ASSOC., P.C.
                           4747 Research Forest Drive,
                                Suite 180, # 303
                             The Woodlands, TX 77381
                             (281) 367-8409 (phone)
                              (281) 367-8401 (fax)
                           [email protected] (e-mail)

                               December 12, 2000

Avalon Funds, Inc.
125 Lincoln Avenue, Suite 100
Santa Fe, New Mexico  87501-2052

Dear Sirs:

As counsel to Avalon Funds, Inc. (the "Company"),  a corporation organized under
the laws of the State of  Maryland,  I have been asked to render my opinion with
respect to the issuance of an indefinite number of shares of beneficial interest
of the Company (the "Shares") representing  proportionate interests in The Water
Fund (the "Fund"). The Shares of the Fund are a series of the Company consisting
of one class of  shares,  all as more  fully  described  in the  Prospectus  and
Statement of Additional  Information contained in the Registration  Statement on
Form N-1A, to which this opinion is an exhibit,  to be filed with the Securities
and Exchange Commission.

I have examined the Company's  Articles of  Incorporation,  the  Prospectus  and
Statement of Additional Information contained in the Registration Statement, and
such other  documents,  records and  certificates  as deemed  necessary  for the
purposes of this opinion.

Based on the  foregoing,  I am of the  opinion  that the  Shares,  when  issued,
delivered  and  paid for in  accordance  with the  terms of the  Prospectus  and
Statement of Additional  Information,  will be legally  issued,  fully paid, and
non-assessable by the Company.

Further,  I give my  permission  to  include  this  opinion as an exhibit to the
Company's Registration Statement on Form N-1A.

Very Truly Yours,


David D. Jones
Attorney & Counselor at Law

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