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Jody M. Walker
7841 South Garfield Way
Littleton, Colorado 80122
Telephone (303) 850-7637
Facsimile (303) 220-9902
June 26, 2000
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Dear Sirs:
Re: OPINION RE: LEGALITY AND CONSENT OF COUNSEL TO USE OF NAME IN
THE POST EFFECTIVE AMENDMENT 1 TO THE REGISTRATION STATEMENT ON FORM
SB-2 OF SEA SHELL GALLERIES, INC.
I am securities counsel for the above mentioned Company and I have
prepared the registration statement on Form SB-2 and any amendments. I
hereby consent to the inclusion and reference of my name and to a
discussion of the opinion in the prospectus and the reproduction of the
opinion in an exhibit in the Registration Statement on Form SB-2 and
any amendments for Sea Shell Galleries, Inc.
It is my opinion that the securities of Sea Shell Galleries, Inc. and
those which are registered with the Securities and Exchange Commission
pursuant to Form SB-2 Registration Statement of Sea Shell Galleries,
Inc. have been legally issued and will be, when sold, legally issued,
fully paid and non-assessable.
Yours very truly,
/s/Jody M. Walker
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Jody M. Walker
