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[Letterhead of SUTHERLAND ASBILL & BRENNAN]
May 5, 2000
VIA EDGAR
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Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
RE: Separate Account D of Paragon Life Insurance Company
(File No. 333-80393)
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Gentlemen:
On behalf of the above-referenced registrant, and in lieu of filing a
prospectus pursuant to Rule 497(b) under the Securities Act of 1933, as amended
(the "Act"), I hereby certify pursuant to Rule 497(j) under the Act:
(1) that the form of prospectus that would have been filed under Rule
497(b) would not have differed from the prospectus contained in the
registrant's most recent registration statement; and
(2) that the registrant electronically filed the text of the most recent
registration statement with the Securities and Exchange Commission via
EDGAR on April 28, 2000.
If you have any questions, please contact the undersigned at (202)
383-0261.
Sincerely,
/s/ Lloyd F. Bernard
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Lloyd F. Bernard
Cc: Elizabeth Rich
