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EXHIBIT 99.15
October 6, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549
RE: REPRESENTATION OF COUNSEL FOR SAFECO LIFE INSURANCE COMPANY ("SAFECO LIFE")
AND ITS SAFECO SEPARATE ACCOUNT C ("SEPARATE ACCOUNT") PRE-EFFECTIVE AMENDMENT
NO. 1, FORM N-4
FILE NOS. 333-41622 AND 811-8052
Commissioners:
SAFECO and its Separate Account believe that the filing of Pre-Effective
Amendment No. 1 is consistent with the purposes and requirements for filing
under Rule 485(a) under the Securities Act of 1933 ("1933 Act"). This
representation is based on the fact that the changes included in this
Pre-Effective Amendment No. 1 are consistent with the purposes and requirements
described in the adopting release for the changes to Rule 485 (IC-Rel. 20486).
Based on the above, the filing of Pre-Effective Amendment No. 1 is made pursuant
to Rule 485(a) of the 1933 Act and has been requested to become effective on
October 9, 2000. The undersigned has prepared and reviewed Pre-Effective
Amendment No. 1, and it is his opinion that Pre-Effective Amendment No. 1 does
not contain disclosures which would render it ineligible to become effective
pursuant to paragraph (a) of Rule 485.
Sincerely,
/s/ William E. Crawford
William E. Crawford
Counsel
