Exhibit 5.1

                      OPINION AND CONSENT OF LEGAL COUNSEL

                            The O'Neal Law Firm, P.C.
                                  June 30, 2004
12 to 20 Plus, Inc..


Ladies and Gentlemen:

I have  acted as  counsel  to 12 to 20 Plus,  Inc.,  a Nevada  corporation  (the
"Company"),  in connection  with the  preparation and filing with the Securities
and Exchange  Commission (the "Commission") of a Registration  Statement on Form
SB-2, Registration No. 333- (the "Registration Statement"), as amended, pursuant
to which the Company is registering under the Securities Act of 1933, as amended
(the "Securities  Act"), up to 25,000,000 shares of its common stock,  $.001 par
value  per share  (the  "Shares")  which  may be  issued  from time to time on a
delayed or continuous  basis pursuant to Rule 415 under the Securities Act. This
opinion is being  rendered  in  connection  with the filing of the  Registration
Statement.  All  capitalized  terms used herein and not otherwise  defined shall
have the respective meanings given to them in the Registration Statement.

In connection  with this opinion,  I have examined the Company's  Certificate of
Incorporation,  as amended,  and By-laws, as amended;  and such other records of
the  corporate  proceedings  of the Company and  certificates  of the  Company's
officers as I deemed relevant;  and the Registration  Statement and the exhibits
filed with the Commission.

In my examination,  I have assumed the genuineness of all signatures,  the legal
capacity of natural persons,  the authenticity of all documents  submitted to me
as originals, the conformity to original documents of all documents submitted to
me as certified or photostatic  copies and the  authenticity of the originals of
such copies.

Based upon the foregoing,  and subject to the  limitations set forth below, I am
of the opinion that, once (i) the Registration Statement, as amended, has become
effective  under  the  Securities  Act,  (ii) the  Shares  have  been  issued as
contemplated by the Registration  Statement,  and (iii) the Company has received
the  consideration in the manner described in the  Registration  Statement,  the
Shares will be duly and validly issued, fully paid and non-assessable  shares of
the Common Stock.

I am an attorney licensed to practice in the State of Arizona.  I do not express
any  opinion as to the laws of any other  jurisdiction  other  than the  General
Corporation Law of the State of Nevada (the "NVCL") and U.S. federal  securities
law. No opinion is  expressed  herein with respect to the  qualification  of the
Shares  under  the  securities  or blue  sky laws of any  state  or any  foreign
jurisdiction.  The  Securities  may be issued  from time to time on a delayed or
continuous  basis, but this opinion is limited to the laws,  including the rules
and regulations thereunder, as in effect on the date hereof.

It is  understood  that this opinion is to be used only in  connection  with the
offer and sale of the Shares while the Registration Statement is in effect. This
opinion  is based upon  currently  existing  statutes,  rules,  regulations  and
judicial decisions, and I disclaim any obligation to advise you of any change in
any of these sources of law or subsequent  legal or factual  developments  which
might affect any matters or opinions set forth herein.

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I  understand  that  you  wish  to  file  this  opinion  as an  exhibit  to  the
Registration Statement, and I hereby consent thereto.


Very truly yours,


/s/  William D. O'Neal  Esq.
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     William D. O'Neal,  Esq.




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