<PAGE>
[Aetna Logo] Aetna Inc.
[Aetna Letterhead] 151 Farmington Avenue
Hartford, CT 06156-8975
J. NEIL MCMURDIE
Counsel
AFS Law, TS31
December 13, 2000 (860) 273-1672
Fax: (860) 273-3227
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: AETNA INSURANCE COMPANY OF AMERICA AND ITS VARIABLE ANNUITY ACCOUNT I
POST EFFECTIVE AMENDMENT NO. 12 TO REGISTRATION STATEMENT ON FORM N-4
PROSPECTUS TITLE: AICA MARATHON PLUS - GROUP AND INDIVIDUAL DEFERRED
VARIABLE ANNUITY CONTRACTS
FILE NOS. 33-59749 AND 811-8582
Dear Sir or Madam:
The undersigned serves as counsel to Aetna Insurance Company of America, a
Connecticut life insurance company (the "Company"). It is my understanding that
the Company, as depositor, has registered an indefinite amount of securities
(the "Securities") under the Securities Act of 1933 (the "Securities Act") as
provided in Rule 24f-2 under the Investment Company Act of 1940 (the "Investment
Company Act").
In connection with this opinion, I have reviewed the N-4 Registration Statement
as amended to the date hereof and this Post-Effective Amendment No. 12. I have
also examined originals or copies, certified or otherwise identified to my
satisfaction, of such documents, trust records and other instruments I have
deemed necessary or appropriate for the purpose of rendering this opinion. For
purposes of such examination, I have assumed the genuineness of all signatures
on original documents and the conformity to the original of all copies.
I am admitted to practice law in Connecticut, and do not purport to be an expert
on the laws of any other state. My opinion herein as to any other law is based
upon a limited inquiry thereof which I have deemed appropriate under the
circumstances.
<PAGE>
Based upon the foregoing, and, assuming the Securities are sold in accordance
with the provisions of the prospectus, I am of the opinion that the Securities
being registered will be legally issued and will represent binding obligations
of the Company.
I consent to the filing of this opinion as an exhibit to the Registration
Statement.
Very truly yours,
/s/ J. Neil McMurdie
J. Neil McMurdie
Counsel
