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Aetna Logo
Aetna Letterhead EX-99-B.9
AETNA Aetna Inc.
Financial Services 151 Farmington Avenue
Hartford, CT 08156-8975
MICHAEL A. PIGNATELLA
Counsel
AFS Law, TS31
December 13, 2000 (860) 273-0261
Fax: (860) 273-9407
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. 2 TO REGISTRATION STATEMENT ON FORM N-4
PROSPECTUS TITLE: RETIREMENT OPTIONS FOR EDUCATION INSTITUTIONS
FILE NOS. 333-87131 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
and Post-Effective Amendment No. 2. 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.
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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/ Michael A. Pignatella
Michael A. Pignatella
