EX-99.(I)(22) 89 d68235exv99wxiyx22y.txt OPINION AND CONSENT OF COUNSEL WITH RESPECT TO JANUS INVESTMENT FUND CLASS A,C,R,S AND I SHARES, AS APPLICABLE, DATED JULY 2, 2009 Exhibit (i)(22) July 2, 2009 Janus Investment Fund 151 Detroit Street Denver, CO 80206-4805 Re: Public Offering of Janus Investment Fund Class A, C, R, S, and I Shares, as applicable Gentlemen: I have acted as Vice President and Chief Legal Counsel for Janus Investment Fund, a Massachusetts business trust (the "Trust"), in connection with the filing with the Securities and Exchange Commission of a post-effective amendment to the Trust's registration statement with respect to the proposed sale of beneficial interest, $0.01 par value, of Class A Shares, Class R Shares, Class C Shares, Class S Shares and Class I Shares, as applicable, (the "Shares"), as separate classes of shares of the series of the Trust shown below:
FUND SHARE CLASSES ------------------------------------ ------------------- INTECH Risk-Managed Core Fund Class A, C, S, I Janus Balanced Fund Class A, C, R, S, I Janus Contrarian Fund Class A, C, R, S, I Janus Enterprise Fund Class A, C, R, S, I Janus Flexible Bond Fund Class A, C, R, S, I Janus Fund Class A, C, R, S, I Janus Global Life Sciences Fund Class A, C, S, I Janus Global Opportunities Fund Class A, C, S, I Janus Global Research Fund Class A, C, S, I Janus Global Technology Fund Class A, C, S, I Janus Growth and Income Fund Class A, C, R, S, I Janus High-Yield Fund Class A, C, R, S, I Janus Research Core Fund Class A, C, R, S, I Janus Research Fund Class A, C, S, I Janus Orion Fund Class A, C, R, S, I Janus Overseas Fund Class A, C, R, S, I Janus Short-Term Bond Fund Class A, C, S, I Janus Smart Portfolio - Conservative Class A, C, S, I Janus Smart Portfolio - Growth Class A, C, S, I Janus Smart Portfolio - Moderate Class A, C, S, I Janus Triton Fund Class A, C, R, S, I Janus Worldwide Fund Class A, C, R, S, I Perkins Mid Cap Value Fund Class A, C, R, S, I Perkins Small Cap Value Fund Class A, C, R, S, I
I have examined the Trust's Amended and Restated Trust Instrument and Amended and Restated Bylaws, each as may be further amended, the proceedings of its trustees relating to the authorization, issuance and proposed sale of the Shares, and such other records and documents as I have deemed relevant. Based upon such examination, it is my opinion that upon the issuance and sale of the Shares in the manner contemplated by the aforesaid post-effective amendment to the Trust's registration statement, such Shares will be legally issued, fully paid and nonassessable. I hereby consent to the filing of this opinion as an exhibit to the above-referenced registration statement. This opinion is for the exclusive use of the Trust in connection with the filing of such post-effective amendment to the Trust's registration statement to establish and designate the Fund and its Shares with the Securities and Exchange Commission (and certain state securities commissions) and is not to be used, circulated, quoted, relied upon or otherwise referred to by any other person or for any other purpose. This opinion is given as of the date hereof and I render no opinion and disclaim any obligation to revise or supplement this opinion based upon any change in applicable law or any factual matter that occurs or comes to my attention after the date hereof. Very truly yours, /s/ Stephanie Grauerholz-Lofton Stephanie Grauerholz-Lofton Chief Legal Counsel, Vice President and Secretary 2