EXHIBIT 5









                                November 15, 2007


Liquor Group Wholesale, Inc.
4600 Touchton Road, Suite 1150
Jacksonville, FL 32246


This letter will constitute an opinion upon the legality of the sale by certain
selling shareholders of Liquor Group Wholesale, Inc., a Colorado corporation
(the "Company"), of up to 2,562,035 shares of common stock, all as referred to
in the Registration Statement on Form SB-2 filed by the Company with the
Securities and Exchange Commission.

We have examined the Articles of Incorporation, the Bylaws and the minutes of
the Board of Directors of the Company and the applicable laws of the State of
Colorado, and a copy of the Registration Statement. In our opinion, the Company
was authorized to issue the shares of stock mentioned above and such shares,
when sold, will represent fully paid and non-assessable shares of the Company's
common stock.

Very truly yours,

HART & TRINEN

William T. Hart