L O S  A N G E L E S,  C A   S A N  F R A N C I S C O,  C A W I L M I N G T O N,  D E N E W  Y O R K,  N Y H O U S T O N,  T X   10100 SANTA MONICA BLVD. 13th FLOOR LOS ANGELES CALIFORNIA 90067   SAN FRANCISCO 150 CALIFORNIA STREET 15th FLOOR SAN FRANCISCO CALIFORNIA 94111-4500   DELAWARE 919 NORTH MARKET STREET 17th FLOOR P.O. BOX 8705 WILMINGTON DELAWARE 19899-8705   NEW YORK 780 THIRD AVENUE 34th FLOOR NEW YORK NEW YORK 10017-2024   HOUSTON 440 LOUISIANA STREET SUITE 900 HOUSTON TEXAS  77002

EXHIBIT 5.1   October 23, 2024   Creative Medical Technology Holdings, Inc. 211 E Osborn Road Phoenix, Arizona 85012   Re: Prospectus Supplement to Registration Statement on Form S-3 (Registration      No. 333-282512)   Ladies and Gentlemen:   We have acted as counsel to Creative Medical Technology Holdings, Inc., a Nevada corporation (the “Company”), in connection with (i) the preparation and filing with the Securities and Exchange Commission (the “Commission”) of a Registration Statement on Form S-3 (Registration No. 333-282298) which was declared effective by the Commission on October 15, 2024 (the “Registration Statement”) and the prospectus therein (the “Base Prospectus”), relating to the offering from time to time, pursuant to Rule 415 of the General Rules and Regulations of the Commission promulgated under the Securities Act of 1933, as amended (the “Securities Act”), of securities of the Company with an aggregate offering price of up to $50,000,000; and (ii) the Prospectus Supplement of the Base Prospectus, dated October 22, 2024 (the “Prospectus Supplement”), filed with the Commission relating to the issuance and sale by the Company of 418,552 shares of the Company’s common stock, par value $0.001 per share (the “Shares”) pursuant to that certain Securities Purchase Agreement, dated October 22, 2024 between the Company and the investors named therein (the “Purchase Agreement”). The Purchase Agreement will be filed as an exhibit to a Current Report on Form 8-K (the “Form 8-K”) and incorporated by reference into the Registration Statement.   In connection with this opinion, we have examined instruments, documents, certificates and records which we have deemed relevant and necessary for the basis of our opinion hereinafter expressed including (a) the Registration Statement, including the exhibits thereto, the Base Prospectus, and the Prospectus Supplement, (b) the Company’s Articles of Incorporation, as amended to date, (c) the Company’s Bylaws, (d) certain resolutions of the Board of Directors of the Company and (e) such other documents, corporate records, and instruments as we have deemed necessary for purposes of rendering the opinions set forth herein.   As to certain factual matters, we have relied upon certificates of the officers of the Company and have not sought to independently verify such matters. In such examination, we have assumed (a) the authenticity of original documents and the genuineness of all signatures, including signatures made and/or transmitted using electronic signature technology (e.g., via DocuSign or similar electronic signature technology); (b) the conformity to the originals of all documents submitted to us as copies; (c) the truth, accuracy, and completeness of the information, representations and warranties contained in the records, documents, instruments and certificates we have reviewed; (d) the legal capacity of all natural persons; (e) the Company will issue and deliver the Shares in the manner contemplated by the Registration Statement, the Base Prospectus, Prospectus Supplement and the Purchase Agreement against payment of valid consideration therefor; (f) all Shares will be issued in compliance with applicable federal and state securities laws; and (g) the obligations of parties to the Agreement other than the Company are valid, binding and enforceable. Based on the foregoing, and subject to the qualifications and limitations stated herein, it is our opinion that the Shares have been duly authorized and, when issued and sold by the Company in accordance with the terms of the Purchase Agreement, will be validly issued, fully paid and nonassessable.    We express no opinion as to the laws of any jurisdiction, other than the law of the State of New York and Chapter 78 of the Nevada Revised Statutes.   We hereby consent to the filing of this opinion with the Commission as Exhibit 5.1 to the Company’s Form 8-K and to the incorporation by reference of this opinion in the Registration Statement, and to the reference to our firm under the caption “Legal Matters” in the Prospectus Supplement. In giving this consent, we do not thereby admit that we are included in the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission thereunder.    This opinion is expressed as of the date hereof, and we disclaim any undertaking to advise you of any subsequent changes in the facts stated or assumed herein or of any subsequent changes in applicable law.