MANUFACTURERS INVESTMENT TRUST
485BPOS, EX-99.(I)(9), 2000-10-27
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                                                               EXHIBIT 99.(i)(9)




            THE MANUFACTURERS LIFE INSURANCE COMPANY OF NORTH AMERICA
                                73 TREMONT STREET
                           BOSTON, MASSACHUSETTS 02108




October 27, 2000


To Whom it may concern:

This opinion is written in reference to the shares of beneficial interest, $.01
par value (the "Shares") of the following series of Manufacturers Investment
Trust, a Massachusetts business trust (the "Trust"), to be offered and sold
pursuant to a Registration Statement on Form N-1A (registration no. 2-94157)
(the "Registration Statement") filed by the Trust pursuant to the Securities Act
of 1933:

CAPITAL APPRECIATION

I have examined such records and documents and reviewed such questions of law as
I deemed necessary for purposes of this opinion.

         1. The Trust has been duly recorded under the laws of the Commonwealth
of Massachusetts and is a validly existing Massachusetts business trust.

         2. The Shares have been duly authorized and, when sold, issued and paid
for in the manner contemplated by the Registration Statement, will be legally
issued, fully paid and non-assessable.

I consent to the filing of this opinion with the Securities and Exchange
Commission as an exhibit to the Registration Statement.

Very truly yours,

/s/Betsy Anne Seel

Betsy Anne Seel, Esq.






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