INTEGRATED
FUND SERVICES, INC.
December 20, 2000
The Appleton Funds
45 Milk Street, Eighth Floor
Boston, MA 02109
Ladies and Gentlemen:
You have requested my opinion in connection with the registration by The
Appleton Funds, an Ohio business trust (the "Trust"), of an indefinite number of
shares (the "Shares") of beneficial interest of the Appleton Equity Growth Fund,
authorized by the Trust's Agreement and Declaration of Trust, which has been
filed with the Securities and Exchange Commission as an exhibit to the Trust's
registration statement on Form N-1A (File No. 811-10201), as amended (the
"Registration Statement"), under the Securities Act of 1933 and the Investment
Company Act of 1940.
I have examined and relied upon originals or copies, certified or otherwise
identified to my satisfaction, of such records, agreements, documents and other
instruments and certificates or comparable documents of public officials and of
officers and representatives of the Trust, and I have made such inquiries of the
officers and representatives of the Trust, as I have deemed relevant and
necessary as the basis for the opinion hereinafter set forth.
In such examination, I have assumed, without independent verification, the
genuineness of all signatures (whether original or photostatic) and the
authenticity of all documents submitted to me as originals and the conformity to
authentic original documents of all documents submitted to me as certified or
photostatic copies. As to all questions of fact material to such opinion, I have
relied upon the certificates referred to hereinabove. I have assumed, without
independent verification, the accuracy of the relevant facts stated therein.
This letter expresses my opinion as to the provisions of the Trust's Agreement
and Declaration of Trust and the laws of the State of Ohio applying to business
trusts generally, but does not extend to the Ohio Securities Act or to federal
securities or other laws.
Integrated Fund Services, Inc. o 221 East Fourth Street o Cincinnati, Ohio 45202
o 513-362-8000 o 800-543-8721 o www.integratedfundservices.com
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The Appleton Funds
December 20, 2000
Page Two
Based on the foregoing, and subject to the qualifications set forth herein, I am
of the opinion that the Shares have been duly and validly authorized, and, when
issued and delivered as described in the Registration Statement, will be fully
paid and nonassessable by the Trust.
I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement. In giving such consent, I do not thereby admit that I come within the
category of persons whose consent is required under Section 7 of the Securities
Act of 1933 or under the rules and regulations of the Securities and Exchange
Commission promulgated thereunder.
Very truly yours,
/s/ Tina D. Hosking
Tina D. Hosking
Vice President and Associate General Counsel
