[THE LEBRECHT GROUP APLC, LETTERHEAD]



                                November 15, 2001

M-GAB  Development  Corporation
1059  E.  Skyler  Drive
Draper,  Utah  84020

RE:     M-GAB  DEVELOPMENT  CORPORATION  REGISTRATION STATEMENT ON FORM SB-2 FOR
2,463,000  SHARES  OF  COMMON  STOCK

Ladies  and  Gentlemen:

     We  have  acted  as  counsel  to  M-GAB  Development Corporation, a Florida
corporation  (the  "Company"), in connection with the proposed issuance and sale
by  (i) the Company of up to 2,000,000 shares of the Company's Common Stock, and
(ii)  thirteen individuals of up to 463,000 shares of the Company's common stock
(collectively,  the  "Securities")  pursuant  to  the  Company's  Registration
Statement  on Form SB-2 (the "Registration Statement") filed with the Securities
and  Exchange  Commission  under  the  Securities  Act  of 1933, as amended (the
"Act").

     This opinion is being furnished in accordance with the requirements of Item
27  of  Form  SB-2  and  Item  601(b)(5)(i)  of  Regulation  S-B.

     We  have  reviewed  the  Company's  charter  documents  and  the  corporate
proceedings taken by the Company in connection with the issuance and sale of the
Securities.  Based  on  such  review,  we are of the opinion that the Securities
have  been  duly  authorized,  and if, as and when issued in accordance with the
Registration  Statement  and the related prospectus (as amended and supplemented
through  the  date  of  issuance)  will  be  legally  issued,  fully  paid  and
nonassessable.

     We  consent  to  the  filing  of  this opinion letter as Exhibit 5.1 to the
Registration  Statement  and  to  the  reference  to this firm under the caption
"Legal  Matters"  in the prospectus which is part of the Registration Statement.
In  giving this consent, we do not thereby admit that we are within the category
of  persons  whose consent is required under Section 7 of the Act, the rules and
regulations of the Securities and Exchange Commission promulgated thereunder, or
Item  509  of  Regulation  S-B.

     This  opinion  letter is rendered as of the date first written above and we
disclaim  any  obligation  to  advise  you  of  facts,  circumstances, events or
developments  which  hereafter  may  be  brought  to our attention and which may
alter,  affect or modify the opinion expressed herein.  Our opinion is expressly
limited  to  the  matters  set  forth above and we render no opinion, whether by
implication or otherwise, as to any other matters relating to the Company or the
Securities.

                         Sincerely,

                         /s/  The  Lebrecht  Group,  APLC
                         The  Lebrecht  Group,  APLC