Exhibit 5.1

                      SICHENZIA ROSS FRIEDMAN FERENCE LLP
                                ATTORNEYS AT LAW

October 26, 2005

VIA ELECTRONIC TRANSMISSION
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

         Re:  APO Health, Inc.
              Form S-8 Registration Statement
              -------------------------------

Ladies and Gentlemen:

     We refer to the  above-captioned  registration  statement  on Form S-8 (the
"Registration  Statement")  under the  Securities  Act of 1933,  as amended (the
"Securities  Act"),  filed  by APO  Health,  Inc.,  a  Nevada  corporation  (the
"Company"), with the Securities and Exchange Commission on October 26, 2005.

     We have  examined the  originals,  photocopies,  certified  copies or other
evidence of such records of the Company, certificates of officers of the Company
and  public  officials,  and other  documents  as we have  deemed  relevant  and
necessary as a basis for the opinion hereinafter expressed. In such examination,
we have assumed the  genuineness  of all  signatures,  the  authenticity  of all
documents   submitted  to  us  as  certified   copies  or  photocopies  and  the
authenticity of the originals of such latter documents.

     Based on our  examination  mentioned  above, we are of the opinion that the
securities being  registered to be sold pursuant to the  Registration  Statement
are duly  authorized  and will be,  when  sold in the  manner  described  in the
Registration  Statement,   legally  and  validly  issued,  and  fully  paid  and
non-assessable.

     We hereby  consent  to the filing of this  opinion  as  Exhibit  5.1 to the
Registration  Statement. In giving the foregoing consent, we do not hereby admit
that we are in the category of persons whose consent is required under Section 7
of the  Securities  Act,  or the rules and  regulations  of the  Securities  and
Exchange Commission.

                                   Very truly yours,

                                   /s/ Sichenzia Ross Friedman Ference LLP
                                   ---------------------------------------
                                   Sichenzia Ross Friedman Ference LLP



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