Exhibit 5.1 AMARAL LAW FIRM P.O. BOX 917086 BOCA RATON, FLORIDA 33497-1086 TELEPHONE (561) 479-4775 TELECOPIER(561) 477-3694 May 20, 2002 Bernard, Allan & Edwards, Inc. 1016 Shore Acres Drive Leesburg, Florida 34748 Re: Opinion Regarding Legality of Common Stock Ladies and Gentlemen: We have examined the Registration Statement on Form S-8 (the "Registration Statement") to be filed by Bernard, Allan & Edwards, Inc. the "Company"), with the Securities and Exchange Commission ("Commission"). It is our understanding that the Registration Statement is to be filed in connection with the registration under the Securities Act of 1933, as amended (the "1933 Act"), of shares of common stock ("Common Stock") to be sold by certain selling shareholders We have examined original or copies, certified or otherwise identified to our satisfaction, of such documents, corporate records and other instruments as we have deemed necessary for the purposes of this opinion. For the purposes of this opinion, we have assumed the authenticity of all documents submitted to us and the genuineness of the signatures of persons signing all documents in connection with which this opinion is rendered, the authority of such persons signing on behalf of the parties thereto, and the due authorization, execution and delivery of all documents by the parties thereto. Based upon the foregoing, we are of the opinion that: when, as and if (i) the Registration Statement shall have become effective pursuant to the provisions of the 1933 Act, (ii) the Company or the selling shareholders shall have received payment in full for their common stock; (iii) the common stock shall have been issued in the form and containing the terms described in the Registration Statement, and (iv) any legally required consents, approvals, authorizations or other orders of the Commission and any other regulatory authority shall have been obtained, the common stock, when sold, will be legally issued, fully paid and nonassessable. We consent to the use of this opinion as an exhibit to the Form S-8 Registration Statement and to the use of our name in the Form S-8 Registration Statement. We do not find it necessary for the purposes of this opinion, and accordingly we do not purport to cover herein, the application of the securities or "Blue Sky" laws of the various states to the sale of the common stock. This opinion is furnished to you and to purchasers in this offering in connection with the filing of the Form SB-2 Registration Statement, and is not to be used, circulated, quoted or otherwise relied upon for any other purpose. Very truly yours, /s/Amaral Law Firm