EX-23.2                                             CONSENT OF COUNSEL

                              Brian F. Faulkner
                       A Professional Law Corporation
                       27127 Calle Arroyo, Suite 1923
                    San Juan Capistrano, California 92675
                               (949) 240-1361


January 30, 2004


U.S. Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:  Avery Sports Turf, Inc. - Form S-8 POS

Dear Sir/Madame:

I have acted as counsel to Avery Sports Turf, Inc., a Delaware
corporation ("Company"), in connection with its Registration Statement
on Form S-8 POS relating to the registration of 30,000,000 shares of
its common stock ("Shares"), $0.001 par value per Share, which are
issuable pursuant to the Company's Non-Employee Directors and
Consultants Retainer Stock Plan.  I hereby consent to all references
to my firm included in this Registration Statement, including the
opinion of legality.

                                       Sincerely,


                                       /s/  Brian F. Faulkner
                                       Brian F. Faulkner, Esq.



