▇▇▇▇▇▇▇▇ ATLANTA CINCINNATI COLUMBUS NEW YORK
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▇▇▇▇ BRUSSELS CLEVELAND DAYTON WASHINGTON, D.C.
July 30, 2007
The Santa ▇▇▇▇▇▇▇ Group of Mutual Funds, Inc.
▇▇▇ ▇▇▇▇▇ ▇▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇
▇▇▇▇▇▇▇▇, ▇▇ ▇▇▇▇▇
RE: Santa ▇▇▇▇▇▇▇ Group of Mutual Funds, Inc.
File Nos. 33-56546 and 811-07414
Gentlemen:
A legal opinion that we prepared was filed with Post-Effective Amendment
No. 14 to the Santa ▇▇▇▇▇▇▇ Group of Mutual Funds, Inc.'s Registration Statement
(the "Legal Opinion"). We hereby give you our consent to incorporate by
reference the Legal Opinion into Post-Effective Amendment No. 19 under the
Securities Act of 1933, Post-Effective Amendment No. 24 under the Investment
Company Act of 1940 (the "Amendment"), and consent to all references to us in
the Amendment.
Very truly yours,
/s/ ▇▇▇▇▇▇▇▇ ▇▇▇▇ LLP
▇▇▇▇▇▇▇▇ ▇▇▇▇ LLP