[CUTLER LAW GROUP LETTERHEAD]

                                May 1, 2002

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  SB-2  under  the  Securities Act of 1933 (the "Registration
Statement"),  which  relates  to  the  resale  of  up  to  2,205,360 shares (the
Registered  Securities) of the Company.   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
under   applicable   federal   and   California   state   law,  fully  paid  and
nonassessable.

     We acknowledge that we are referred to under the heading "Legal Matters" in
the  Prospectus  which  is  a  part  of  the Registrant's Form SB-2 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.



                               /s/ Cutler Law Group

                              CUTLER  LAW  GROUP