[LETTERHEAD  OF  CUTLER  LAW  GROUP]


                           April 12,  2000

Securities  and  Exchange  Commission
Division  of  Corporate  Finance
Washington,  D.C.  20549

     Re:     Creative Host Services,  Inc.

Ladies  and  Gentlemen:

   This office represents Creative Host Services, Inc., a California corporation
(the "Registrant") in connection with the Registrant's Registration Statement on
Form  S-8  under  the  Securities  Act  of  1933 (the "Registration Statement"),
which  relates  to  the  resale  of  up  to  20,000  shares  by  certain selling
shareholders  (the  "Registered  Securities").   In  connection  with  our
representation,  we  have  examined  such  documents and undertaken such further
inquiry  as  we  consider necessary  for  rendering  the opinion hereinafter set
forth.

     Based upon the foregoing, it is our opinion that the Registered Securities,
when  issued as set forth in the Registration Statement, will be legally issued,
fully  paid  and  nonassessable.

     We acknowledge that we are referred to under the heading "Legal Matters" in
the  Resale Prospectus which is a part of the Registrant's Form S-8 Registration
Statement  relating  to the Registered Securities, and we hereby consent to such
use of our name in such Registration Statement and to the filing of this opinion
as  Exhibit  5  to  the  Registration  Statement  and with such state regulatory
agencies  in  such  states  as  may  require  such filing in connection with the
registration  of  the  Registered  Securities for offer and sale in such states.

                                    Very  truly  yours,

                                    /s/  Cutler  Law  Group

                                    Cutler  Law  Group