Exhibit 11

                                [Form of Opinion]
                                     Dechert
                              1775 Eye Street, N.W.
                             Washington, D.C. 20006


__________, 200_

Board of Trustees
Pilgrim Equity Trust
7337 E. Doubletree Ranch Road
Scottsdale, AZ 85258-2034

Re:  PILGRIM EQUITY TRUST, ON BEHALF OF PILGRIM MIDCAP OPPORTUNITIES FUND

Dear Ladies and Gentlemen:

We have acted as counsel to Pilgrim Equity Trust, a Massachusetts business trust
(the "Trust"), and we have a general familiarity with the Trust's business
operations, practices and procedures. You have asked for our opinion regarding
the issuance of shares of beneficial interest by the Trust in connection with
the acquisition by Pilgrim MidCap Opportunities Fund, a series of the Trust, of
the assets of Pilgrim MidCap Growth Fund, a series of Pilgrim Mutual Funds,
which will be registered on a Form N-14 Registration Statement (the
"Registration Statement") to be filed by the Trust with the U.S. 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
Trust 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 Trust being registered under the Securities Act of 1933, as
amended, in the Registration Statement have been duly authorized and will be
legally and validly issued, fully paid and non-assessable by the Trust upon
transfer of the assets of Pilgrim MidCap Growth Fund pursuant to the terms of
the Agreement and Plan of Reorganization included in this 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,