JNL INVESTORS SERIES TRUST
N-1A/A, EX-99.JLEGALOPININ, 2000-11-02
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Blazzard, Grodd & Hasenauer, P.C.

ATTORNEYS AT LAW                           CONNECTICUT OFFICE:
                                           943 POST ROAD EASTo P.O. BOX 5108
NORSE N. BLAZZARD**                        WESTPORT, CONNECTICUT 06881-5108
LESLIE E. GRODD*                                    TELEPHONE (203)226-7866
JUDITH A. HASENAUER**                      FACSIMILE (203)454-4028
WILLIAM E. HASENAUER*
RAYMOND A. O'HARA III                      FLORIDA OFFICE:
LYNN KORMAN STONE                          4401 WEST TRADEWINDS AVENUE-SUITE 207
                                           LAUDERDALE BY THE SEA, FLORIDA 33308
                                           TELEPHONE (954)771-6667
*     Admitted in Connecticut              FACSIMILE (954)771-7689
**    Admitted in Connecticut and Florida


                                November 2, 2000

Board of Trustees
JNL Investors Series Trust
One Corporate Way
Lansing, MI 48951

         Re: Opinion of Counsel - JNL Investors Series Trust

Ladies and Gentlemen:

         You have requested our Opinion of Counsel in connection with the filing
with the Securities and Exchange Commission of Pre-Effective  Amendment No. 1 to
the Registration Statement on Form N-1A with respect to the JNL Investors Series
Trust.

         We have made such examination of the law and have examined such records
and  documents as in our judgment are necessary or  appropriate  to enable us to
render the opinions expressed below.

         We are of the following opinions:

         1.       JNL Investors  Series Trust  ("Trust") is a valid and existing
                  unincorporated  voluntary  association,  commonly  known  as a
                  business trust.

         2.       The Trust is a business  Trust  created and  validly  existing
                  pursuant to the Massachusetts Laws.


<PAGE>
Board of Trustees
JNL Investors Series Trust
November 2, 2000
Page 2

         3.       All of the prescribed Trust procedures for the issuance of the
                  shares have been followed, and, when such shares are issued in
                  accordance with the Prospectus  contained in the  Registration
                  Statement for such shares, all state requirements  relating to
                  such Trust shares will have been  complied  with.

         4.       Upon the acceptance of purchase  payments made by shareholders
                  in   accordance   with  the   Prospectus   contained   in  the
                  Registration  Statement and upon  compliance  with  applicable
                  law, such shareholders will have  legally-issued,  fully paid,
                  non-assessable shares of the Trust.

         You may use this opinion  letter,  or a copy thereof,  as an exhibit to
the Registration.


                                            Sincerely,

                                            BLAZZARD, GRODD & HASENAUER, P.C.



                                            By: /s/RAYMOND A. O'HARA III
                                               -------------------------
                                                 Raymond A. O'Hara III


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