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August 31, 2000
Board of Directors
Integrity Life Insurance Company
515 West Market Street
Louisville, KY 40202
Gentlemen:
This Opinion of Counsel is in connection with the filing with the Securities and
Exchange Commission pursuant to the Securities Act of 1933, as amended, of a
Registration Statement on Form N-4 for the variable annuity contract to be
issued by Integrity Life Insurance Company and its separate account, Separate
Account I of Integrity Life Insurance Company.
We have made such an 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. Integrity Life Insurance Company Separate Account I is a Unit
Investment Trust as that term is defined in Section 4(2) of the
Investment Company Act of 1940 (the "Act"), and is currently
registered with the Securities and Exchange Commission, pursuant to
Section 8(a) of the Act.
2. Upon the acceptance of purchase payments paid by an owner pursuant to
a policy issued in accordance with the prospectus contained in the
registration statement and upon compliance with applicable law, such
an owner will have a legally-issued, fully paid, non-assessable
contractual interest under such policy.
You may use this opinion letter, or a copy thereof, as an exhibit to the
registration statement.
Sincerely
/s/ G. Stephen Wastek
G. Stephen Wastek
Assistant General Counsel
Integrity Life Insurance Company