RICHARDSON & ASSOCIATES
                                ATTORNEYS AT LAW
                           WILSHIRE PALISADES BUILDING
                                1299 OCEAN AVENUE
                                    SUITE 900
                         SANTA MONICA, CALIFORNIA 90401
                            TELEPHONE (310) 393-9992
                            FACSIMILE (310) 393-2004



                                 July 7, 2000



Creative Host Services, Inc.
6355 Ferris Square
Suites G & H
San Diego, California 92126

        RE: CREATIVE HOST SERVICES, INC. - VALIDITY OF ISSUANCE OF SHARES

Ladies and Gentlemen:



       We have acted as special counsel to you in connection with the
registration on Form S-3 (File No. 333-38760 ) under the Securities
Act of 1933, as amended (the "Registration Statement") of 1,103,723 shares of
the Common Stock of Creative Host Services, Inc., a California corporation
(the "Company"), no par value per share, consisting of 264,623 outstanding
shares of the Company's Common Stock (collectively, the "Shares"), and
839,100 shares of the Company's Common Stock issuable upon the exercise of
839,100 outstanding warrants (collectively, the "Warrants") to purchase the
Company's Common Stock. The shares of the Company's Common Stock issuable
upon the exercise of the Warrants are collectively referred to herein as the
"Underlying Shares". You have requested our opinion in connection with the
registration of the Shares and Underlying Shares covered by the Prospectus,
dated July 7, 2000 (the "Prospectus"). In connection with our acting as
counsel, we have examined the laws of the State of California together with
the Warrants entered into by the Company and the Warrantholders attached as
Exhibits 4.2, 4.3 and 4.4 to the Registration Statement, as well as the
Prospectus and certain other documents and instruments prepared on behalf of
the Company as we deemed necessary and relevant in the preparation of our
opinion as hereinafter set forth.



         In our examination, we have assumed the genuineness of all signatures
on original documents and the authenticity of all documents submitted to us as
originals, the conformity to original documents of all documents submitted to us
as certified, conformed or photostatic copies of originals, the authenticity of
such latter documents, and the proper execution, delivery and filing of the
documents referred to in this opinion.






Creative Host Services, Inc.
July 7, 2000
Page Two



         Based upon the foregoing, we are of the opinion that the outstanding
Shares and the Underlying Shares to be issued by the Company pursuant to the
exercise of the Warrants have been and will be duly created, and have been
and will be validly issued shares of the Common Stock, no par value per
share, of the Company. Upon proper exercise of the outstanding Warrants and
payment for the Underlying Shares issuable upon the exercise of the Warrants,
the Underlying Shares will be fully paid and nonassessable.

         For the purposes of this opinion we are assuming the proper
execution of the Warrants and all certificates evidencing the Warrants, and
that the appropriate certificates are duly filed and recorded in every
jurisdiction in which such filing and recordation is required in accordance
with the laws of such jurisdictions. We express no opinion as to the laws of
any state or jurisdiction other than California.

         We consent to the use of this opinion as an exhibit to the Registration
Statement, and we further consent to the use of our name in the Registration
Statement and the Prospectus which is a part of said Registration Statement.

                                 Respectfully submitted,



                                 Mark J. Richardson, Esq.

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