EXHIBIT 5

OPINION RE: LEGALITY

                                Kenneth G. Eade
                                Attorney at Law
                         190 N. Canon Drive, Suite 420
                        Beverly Hills, California 90210
                                 (310) 275-3055


                                February 28, 2007



Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:  City Capital Corporation Form S-8

Dear Sir/Madame:

I have acted as counsel to City Capital Corporation, a Nevada corporation
("Company"), in connection with its Registration Statement on Form S-8
relating to the registration of twenty million (20,000,000) shares of   its
common stock ("Shares"), $0.001 par value per Share, which are issuable
pursuant to the Company's Amended and Restated Non-Employee Directors and
Consultants Retainer Stock Plan (Amendment No. 4).

In my representation I have examined such documents, corporate  records, and
other instruments as I have deemed necessary or  appropriate for purposes of
this opinion, including, but not limited  to, the Articles of Incorporation,
and all amendments thereto, and  Bylaws of the Company.

Based upon and in reliance on the foregoing, and subject to the  qualifications
and assumptions set forth below, it is my opinion that  the Company is duly
organized and validly existing as a corporation  under the laws of the State of
Nevada, and that the Shares, when  issued and sold, will be validly issued,
fully paid, and non-assessable.

My opinion is limited by and subject to the following:

(a)  In rendering my opinion I have assumed that, at the time of  each issuance
and sale of the Shares, the Company will be a  corporation validly existing and
in good standing under the laws  of the State of Nevada.

(b)  In my examination of all documents, certificates and  records, I have
assumed without investigation the authenticity  and completeness of all
documents submitted to me as originals,  the conformity to the originals of all
documents submitted to me  as copies and the authenticity and completeness of
the originals  of all documents submitted to me as copies.  I have also assumed
the genuineness of all signatures, the legal capacity of natural  persons, the
authority of all persons executing documents on  behalf of the parties thereto
other than the Company, and the due  authorization, execution and delivery of
all documents by the  parties thereto other than the Company.  As to matters of
fact  material to this opinion, I have relied upon statements and
representations of representatives of the Company and of public  officials and
have assumed the same to have been properly given  and to be accurate.

(c)  My opinion is based solely on and limited to the federal  laws of the
United States of America and the Nevada Revised  Statutes.  I express no
opinion as to the laws of any other  jurisdiction.


                                            Sincerely,

                                            Kenneth G. Eade
                                            ----------------------
                                            Kenneth G. Eade, Esq.