RICHARDSON & ASSOCIATES
                                ATTORNEYS AT LAW
                           WILSHIRE PALISADES BUILDING
                                1299 OCEAN AVENUE
                                    SUITE 900
                         SANTA MONICA, CALIFORNIA 90401
                            TELEPHONE (310) 393-9992
                            FACSIMILE (310) 393-2004

                                February 10, 2000

Creative Host Services, Inc.
6355 Ferris Square
Suites G & H
San Diego, California 92126

        RE: CREATIVE HOST SERVICES, INC. - VALIDITY OF ISSUANCE OF SHARES

Ladies and Gentlemen:                   :

       We have acted as special counsel to you in connection with the
registration on Form S-3 (File No.___________________ ) under the Securities Act
of 1933, as amended (the "Registration Statement") of 1,835,378 shares of the
Common Stock of Creative Host Services, Inc., a California corporation (the
"Company"), no par value per share, consisting of 1,140,951 outstanding shares
of the Company's Common Stock (collectively, the "Shares"), up to 120,000 shares
of the Company's Common Stock issuable upon the exercise of 120,000 outstanding
warrants (collectively, the "Warrants") to purchase the Company's Common Stock,
and up to 574,427 shares of the Company's Common Stock issuable upon the
conversion of $1,505,000 outstanding principal amount of 12% Secured Convertible
Promissory Notes dated December 21, 1998 (collectively, the "Notes"). The shares
of the Company's Common Stock issuable upon the exercise of the Warrants and
conversion of the Notes are collectively referred to herein as the "Underlying
Shares". You have requested our opinion in connection with the registration of
the Shares and Underlying Shares covered by the Prospectus, dated February 10,
2000 (the "Prospectus"). In connection with our acting as counsel, we have
examined the laws of the State of California together with the Warrant entered
into by the Company and the Warrantholder attached as Exhibit 4.2 to the
Registration Statement and the Notes issued by the Company attached as Exhibit
4.3 to the Registration Statement, as well as the Prospectus and certain other
documents and instruments prepared on behalf of the Company as we deemed
necessary and relevant in the preparation of our opinion as hereinafter set
forth.

         In our examination, we have assumed the genuineness of all signatures
on original documents and the authenticity of all documents submitted to us as
originals, the conformity to original documents of all documents submitted to us
as certified, conformed or photostatic copies of originals, the authenticity of
such latter documents, and the proper execution, delivery and filing of the
documents referred to in this opinion.




Creative Host Services, Inc.
February 10, 2000
Page Two

         Based upon the foregoing, we are of the opinion that the outstanding
Shares and the Underlying Shares to be issued by the Company pursuant to the
conversion of the Notes and the exercise of the Warrants have been and will be
duly created, and have been and will be validly issued shares of the Common
Stock, no par value per share, of the Company. Upon proper exercise of the
outstanding Warrants and payment for the Underlying Shares issuable upon the
exercise of the Warrants, and upon the proper conversion of the Notes, the
Underlying Shares will be fully paid and nonassessable.

         For the purposes of this opinion we are assuming the proper execution
of the Notes and Warrants and all certificates evidencing the Notes and
Warrants, and that the appropriate certificates are duly filed and recorded in
every jurisdiction in which such filing and recordation is required in
accordance with the laws of such jurisdictions. We express no opinion as to the
laws of any state or jurisdiction other than California.

         We consent to the use of this opinion as an exhibit to the Registration
Statement, and we further consent to the use of our name in the Registration
Statement and the Prospectus which is a part of said Registration Statement.

                                 Respectfully submitted,



                                 Mark J. Richardson, Esq.

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