Exhibit 11

                                [Form of Opinion]

                                     Dechert
                              1775 Eye Street, N.W.
                              Washington, D.C. 2006

November 30, 2000


Board of Directors
Pilgrim Gold Fund, Inc.
7337 E. Doubletree Ranch Road
Scottsdale, AZ 85258-2034

Re:  Pilgrim Gold Fund, Inc., on behalf of Pilgrim Gold Fund

Dear Gentlepersons:

We have  acted as  counsel  to  Pilgrim  Gold  Fund,  Inc.  (formerly  Lexington
Goldfund,  Inc.), a Maryland corporation (the "Company"),  and we have a general
familiarity with the Company's  business  operations,  practices and procedures.
You have asked for our opinion  regarding  the issuance of shares of  beneficial
interest by the Company in connection with the acquisition by Pilgrim Gold Fund,
a series of the  Company,  of the assets of  Pilgrim  Silver  Fund,  a series of
Pilgrim Silver Fund, Inc., which will be registered on a Form N-14  Registration
Statement  (the  "Registration  Statement")  to be filed by the Company with the
Securities and Exchange Commission.

We have examined  originals or certified copies, or copies otherwise  identified
to our satisfaction as being true copies,  of various  corporate  records of the
Company  and such other  instruments,  documents  and  records as we have deemed
necessary in order to render this opinion.  We have assumed the  genuineness  of
all  signatures,  the  authenticity  of all  documents  examined  by us and  the
correctness of all statements of fact contained in those documents.

On the basis of the  foregoing,  it is our opinion that the shares of beneficial
interest of the Company being registered under the Securities Act of 1933 in the
Registration Statement have been duly authorized and will be legally and validly
issued, fully paid and non-assessable by the Company upon transfer of the assets
of  Pilgrim  Silver  Fund  pursuant  to the terms of the  Agreement  and Plan of
Reorganization included in the Registration Statement.

We hereby  consent to use of this  opinion  as an  exhibit  to the  Registration
Statement and to all references to our firm therein.

Very truly yours,