DENNIS H. JOHNSTON
                      A Professional Law Corporation
                            9422 Canfiled Drive
                        La Habra, California 90631
                         Telephone (562) 694-5092
                            Fax (562) 694-0412
                         dhjohnston@earthlink.net

August 7, 2007

U.S. Securities and Exchange Commission
450 Fifth Avenue, N.W.
Washington, D.C.  20549

RE:   REGISTRATION STATEMENT ON FORM SB-2 UNDER THE SECURITIES ACT OF 1933
      (THE "REGISTRATION STATEMENT"), OF GRAY CREEK MINING INC., A NEVADA
      CORPORATION (THE "COMPANY")

Dear Gentlepersons:

We have acted as special counsel for the Company for the limited purpose of
rendering this opinion in connection with the registration (pursuant to the
Registration Statement) of 2,250,000 shares (the "Shares") of the common
stock, par value $0.001 per share, of the Company.  We were not engaged to
prepare or review, and we have not prepared or reviewed, any portion of the
Registration Statement.  We express no opinion as to the accuracy or
adequacy of the disclosure contained in the Registration Statement, and we
hereby disclaim any responsibility for the content of the Registration
Statement.

In our capacity as special counsel to the Company, we have examined
originals, or copies certified or otherwise identified to our satisfaction,
of the following documents:

      1.    Certificate of Incorporation of the Company, as amended to
            date;

      2.    By-Laws of the Company, as amended to date;

      3.    The records of corporate proceedings relating to the issuance
            of the Shares; and;

      4.    Such other instruments and documents as we have believed
            necessary for the purpose of rendering the following opinion.

In such examinations, we have assumed the authenticity and completeness of
all documents, certificates and records submitted to us as originals, the
conformity to the original instruments of all documents, certificated and
records submitted to us as copies, and the authenticity and completeness of
the originals of such instruments.

Based on the foregoing, and having due regard for such legal considerations
as we believe


relevant, we are of the opinion that, under applicable law of the State of
Nevada (including statutory, regulatory and case law), the Shares were duly
authorized by all necessary corporate action on the part of the Company,
currently validly issued, fully-paid and nonassessable when sold after the
effectiveness of the Registration Statement..

We hereby consent to the filing of this opinion with the U.S. Securities
and Exchange Commission as Exhibit 5.1 to the Registration Statement.


Very truly yours,
Dennis H. Johnston, Esq.

/s/ Dennis H. Johnston
Dennis H. Johnston
DJ:yf
cc: Client