[STEPP & BEAUCHAMP LLP LETTERHEAD]
Opinion of Counsel and Consent of Counsel
Board of Directors
Food and Beverage Masters (Kazakstan), Inc.
Re: Registration Statement on Form SB-2
Gentlemen: As counsel to Food and Beverage Masters (Kazakstan), Inc., a Delaware
corporation (the "Company"), we have participated in the preparation of the
Company's Registration Statement on Form SB-2 filed with the Securities and
Exchange Commission pursuant to the Securities Act of 1933, as amended, relating
to the registration of 4,000,000 shares of the Company's $.001 par value common
stock owned by the selling security holders (the "Shares"). As counsel to the
Company, we have examined such corporate records, certificates and other
documents of the Company, and made inquiries of such officers of the Company, as
we have deemed necessary or appropriate for purposes of this opinion. Based upon
such examinations, we are of the opinion that the Shares have been and are duly
authorized, validly issued, fully paid and non-assessable shares of the common
stock of the Company. We hereby consent to the inclusion of this opinion as an
exhibit to the Registration Statement on Form SB-2 filed by the Company and the
reference to our firm contained therein under "Legal Matters."
Sincerely,
/s/ Stepp & Beauchamp LLP
Stepp & Beauchamp LLP
Newport Beach, California
