SANTA BARBARA GROUP OF MUTUAL FUNDS INC
485BPOS, EX-99.23.I, 2000-08-01
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                                    EX-23(I)

                           DAVID JONES & ASSOC., P.C.

                                    LAW FIRM

                                [GRAPHIC OMITTED]           (281) 367-8409 phone
4747 Research Forest Drive                              (281) 367-8401 facsimile
Suite 180, # 303                                       [email protected]  email
The Woodlands, TX  77381                               [email protected]  email

Santa Barbara Group of Mutual Funds, Inc.                          July 28, 2000
107 South Fair Oaks, Blvd., Suite 315
Pasadena, California

Dear Sirs:

As counsel to The Santa Barbara Group of Mutual Funds,  Inc. (the "Company"),  a
corporation organized under the laws of the State of Maryland and operating as a
registered management investment company, 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 Bender Growth Fund (the "Fund").  The Shares of the Fund are a series of the
Company  consisting of three classes 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, by-laws, 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.  I also  give my  consent  for the  Company  to
included  this  opinion as an Exhibit to the Trust's  Registration  Statement on
Form N-1A.

Very Truly Yours,

/s/  David D. Jones
-------------------------------
David D. Jones
Attorney & Counselor at Law

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