Exhibit 9
JANUS
100 FILLMORE STREET
DENVER, COLORADO 80206-4928
PH: 303-316-5644
FAX: 303-639-6662
E-MAIL: [email protected]
June 12, 2000
Janus Adviser Series
100 Fillmore Street
Denver, Colorado 80206-4928
Re: Public Offering of Janus Adviser Series Shares (Janus Adviser Growth
Fund; Janus Adviser Aggressive Growth Fund; Janus Adviser Capital
Appreciation Fund; Janus Adviser Balanced Fund; Janus Adviser Equity
Income Fund; Janus Adviser Growth and Income Fund; Janus Adviser
Strategic Value Fund; Janus Adviser International Fund; Janus Adviser
Worldwide Fund; Janus Adviser Flexible Income Fund; and Janus Adviser
Money Market Fund)
Gentlemen:
I have acted as vice president and general counsel for Janus Adviser Series, a
Delaware business trust (the "Trust"), in connection with the filing with the
Securities and Exchange Commission of a registration statement with respect to
the proposed sale of shares of beneficial interest, $0.001 par value (the
"Shares"), of the above-referenced series of the Trust.
I have examined the Trust Instrument and Bylaws, as amended, the proceedings of
its trustees relating to the authorization, issuance and proposed sale of the
Shares, and such other records and documents as I have deemed relevant. Based
upon such examination, it is my opinion that upon the issuance and sale of the
Shares in the manner contemplated by the aforesaid registration statement, such
Shares will be legally issued, fully paid and nonassessable.
I hereby consent to the filing of this opinion as an exhibit to the
above-referenced registration statement. This opinion is for the exclusive use
of the Janus Adviser Series in connection with the filing of such registration
statement with the Securities and Exchange Commission and is not to be used,
circulated, quoted, relied upon or otherwise referred to by any other person or
for any other purpose. This opinion is given as of the date hereof and I render
no opinion and disclaim any obligation to revise or supplement this opinion
based upon any change in applicable law or any factual matter that occurs or
comes to my attention after the date hereof.
Very truly yours,
/s/Thomas A. Early
Thomas A. Early
