PARAGON LIFE INSURANCE CO SEPARATE ACCOUNT D
497J, 1999-05-06
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<PAGE>
 
           STEPHEN E. ROTH
     DIRECT LINE: (202) 383-0158
      Internet: [email protected]



                                  May 6, 1999



VIA EDGAR
- ---------


Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549


Re:       Registrant: Separate Account D of Paragon Life Insurance Company
          File No:  333-36515
          -------------------------------------------------------

Commissioners:

     Pursuant to Rule 497(j) of the Securities Act of 1933, on behalf of the
Registrant, I hereby certify that the form of prospectus dated May 1, 1999, that
would have been filed pursuant to paragraph (b) of Rule 497 does not differ from
that contained in the most recent amendment to the registration statement.

     The text of the most recent amendment has been filed electronically.  If
you have any questions, please contact the undersigned at (202) 383-0158 or
Christine S. Harkey at (202) 383-0485.

                              Sincerely,



                              /s/ Stephen E. Roth
                                  Stephen E. Roth

cc: Elizabeth Rich
    Christine S. Harkey


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