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EXHIBIT
ITEM 23 (i)
[LETTERHEAD OF D'ANCONA & PFLAUM]
January 16, 2001
Davis International Total Return Fund, Inc.
2949 East Elvira Road, Suite 101
Tucson, Arizona 85706
Ladies and Gentlemen:
We have acted as counsel for Davis International Total Return Fund, Inc. (the
"Company") in connection with the registration under the Securities Act of 1933
(the "Act") of an indefinite number of shares of beneficial interest in the
series of the Company designated as Davis International Total Return Fund (the
"Shares") in registration statement No. 33-86578 on Form N-1A (the "Registration
Statement").
In this connection we have examined originals, or copies certified or otherwise
identified to our satisfaction, of such documents, corporate and other records,
certificates and other papers as we deemed it necessary to examine for the
purpose of this opinion, including the Articles of Incorporation and bylaws of
the Company, actions of the Board of Directors authorizing the issuance of
Shares and the Registration Statement.
Based on the foregoing examination, we are of the opinion that upon the issuance
and delivery of the Shares in accordance with the Articles of Incorporation and
the actions of the Board of Directors authorizing the issuance of the Shares,
and the receipt by the Company of the authorized consideration therefor, the
Shares so issued will be validly issued, fully paid and nonassessable.
We consent to the filing of this opinion as an exhibit to the Registration
Statement. In giving this consent, we do not admit that we are in the category
of persons whose consent is required under section 7 of the Act.
Very truly yours,
D'Ancona & Pflaum
By
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Arthur Don, Partner
