EXHIBIT 5.1

                                EVERETT & EVERETT
                         ATTORNEYS AND COUNSELORS AT LAW
                  2812 ERWIN ROAD, SUITE 305      P.O. BOX 3001
                  DURHAM, NC 27705                DURHAM, NC 27715

R.O. EVERETT (1878-1971)
KATHERINE R. EVERETT (1893-1992)
ROBINSON O. EVERETT
SANDRA G. HERRING
SHERRY HONETCUTT EVERETT                                     TEL: (919) 382-2800
LEWIS M. EVERETT                                             FAX: (919) 382-2800
                                November 17, 2008

RE: REGISTRATION STATEMENT ON FORM S-1 OF XTRASAFE, INC.

Ladies and Gentlemen:

         We have been engaged by XtraSafe, Inc., a Florida corporation, in
connection with its registration statement on Form S-1 (the "Registration
Statement") to be filed with the Securities and Exchange Commission and relating
to the registration of 3,000,000 shares of Common Stock, par value $.001
(hereinafter, the "registerable securities"). This opinion is being furnished at
the request of the corporation and in accordance with the requirements of Item
601(b)(5) of Regulation S-K under the Securities Act of 1933, as amended.

         In order to provide this opinion, we have examined and relied upon
original, certified, conformed, Photostat or other copies of the following
documents:

         o  The Amended and Restated Articles of Incorporation ("Articles of
            Incorporation") and the Bylaws as presently in effect ("Bylaws") of
            the company, filed as exhibits 3.1.1 and 3.2, respectively, to the
            Registration Statement;

         o  Records of the corporate proceedings taken to date with respect to
            the authorization and issuance of the registerable securities;

         o  The Registration Statement and the exhibits attached thereto solely
            as they pertain to the registerable securities;

         o  Applicable provisions of the statutes of the State of Florida, the
            corporate laws of the State of Florida, and published judicial and
            administrative interpretations thereof, and;

         o  Such other documents and matters of law as we have deemed necessary
            for the expression of this opinion.

         In all of our examinations, we have assumed the genuineness of all
signatures, the authenticity of all documents submitted to us as original
documents, and the conformity to originals or certified documents of all copies
submitted to us as conformed, Photostat, or other copies. In passing upon
certain corporate records and documents of the Company, we have necessarily
assumed the correctness of the statements made or included therein by the
Company, and we express no opinion thereon. As to the various questions of fact
material to this opinion, we have relied, to the extent we deemed reasonably
appropriate, upon representations or certificates of officers or directors of
the Company, and upon documents, records and instruments furnished to us by the
Company, without independently checking or verifying the accuracy of such
documents, records, and instruments.



         Based upon and subject to the foregoing, we are of the opinion that the
registerable securities, when issued in accordance with their terms and upon
receipt by the Company of the agreed upon consideration therefor, will be
legally issued, fully paid and non-assessable.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement, provided that such consent shall not constitute an
admission that we are an "Expert" within the meaning of the Securities Act of
1933, as amended.

                                        Sincerely,

                                        /s/ Luke Everett

                                        Luke Everett
                                        Everett & Everett Law Firm