[LETTERHEAD  OF  CUTLER  LAW  GROUP]


                              January 31, 2003

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  S-3  under  the  Securities  Act of 1933 (the "Registration
Statement"),  which relates to the resale of up to 452,050 shares by ING Capital
LLC  upon exercise of warrants at $1.87 per share.(the "Registered Securities").
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,
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 S-3 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.

                                              Very  truly  yours,

                                             /s/  Cutler  Law  Group

                                             CUTLER  LAW  GROUP