EXHIBIT 5






                                  July 25, 2008


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 1,962,035 shares of common stock, all as referred to
in the Registration Statement on Form S-1 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
Coloradoapplicable provisions of the Colorado Revised Statutes and the Colorado
Constitution, all reported judicial decisions interpreting the same, and a copy
of the Registration Statement. In our opinion, the shares mentioned above have
been validly issued and such shares are fully paid and non-assessable.


Very truly yours,

HART & TRINEN


/s/ William T. Hart
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William T. Hart