Exhibit 5.1

                                Owen M. Naccarato
                                 Attorney at Law
                           19600 Fairchild, Suite 260
                                Irvine, CA 91612
                   Office: (949) 851-9261 Fax: (949) 851-9262
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June 7, 2002

Kaire Holdings, Inc.

Re:     Opinion of Counsel - Registration Statement on Form S-8

Gentleman:

     I have acted as counsel for Kaire Holdings, Inc. (the "Company"), in
connection with the preparation and filing of the Company's Registration
statement on Form S-8 under the Securities Act of 1933, (the "Registration
Statement"), relating to 25,000,000 shares of the Company's common stock, $.001
par value, (the "common stock"), issuable pursuant to the Amended 2001 Employee
Compensation Plan.

     I have examined the Certificate of Incorporation, as amended, and the
By-Laws of the company and all amendments thereto, the Registration Statement
and originals, or copies certified to my satisfaction, of such records and
meetings, written actions in lieu of meetings, or resolutions adopted at
meetings, of the directors of the Company, and such other documents and
instruments as in my judgement are necessary or appropriate to enable me to
render the opinions expressed below.

     Based on the foregoing examination, I am of the opinion that the shares of
Common Stock issuable with the Plan are duly authorized and, when issued in
accordance with the Plan, will be validly issued, fully paid and nonassessable.

     Further, I consent to the filing of this opinion as an exhibit to the
Registration Statement.

          Very truly yours,


          /s/  Owen Naccarato
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          Owen Naccarato, Esq.