EXHIBIT 5.1

                         Opinion and Consent of Counsel

                                November 12, 2003

Board of Directors
12 to 20 Plus, Inc.
3485 Sacramento Drive
Suite F
San Luis Obispo, California 93401

Ladies:

     You  have  requested  our  opinion  with  respect  to  certain  matters  in
connection  with  the  filing  by 12 to  20  Plus,  Inc.  (the  "Company")  of a
Registration  Statement  on Form S-8  (the  "Registration  Statement")  with the
United States  Securities  and Exchange  Commission  covering the offering of an
aggregate of 5,000,000 shares of the common stock of the Company (the "Shares")

     In  connection  with  this  opinion,  we  have  examined  the  Registration
Statement and the Company's  Amended and Restated  Articles of Incorporation and
By-laws, and such other documents,  records,  certificates,  memoranda and other
instruments,  as we deem necessary as a basis for this opinion.  We have assumed
the genuineness and authenticity of all documents  submitted to us as originals,
the conformity to originals of all documents  submitted to us a copies  thereof,
and the due  execution  and delivery of all  documents,  where due execution and
delivery are a prerequisite to the effectiveness thereof.

     On the  basis of the  foregoing,  and in  reliance  thereon,  we are of the
opinion  that the  shares,  when sold and  issued in  accordance  with the plans
referenced above and the Registration  Statement,  will be validly issued, fully
paid, and non-assessable.

     We consent to the filing of this opinion as an exhibit to the  Registration
Statement.

                                            Sincerely yours,

                                            /s/THE O'NEAL LAW FIRM, P.C.
                                            ----------------------------
                                            Phoenix, Arizona