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EXHIBIT 9
First Sun America Life Insurance Company
1 SunAmerica Center
Los Angeles, CA 90067-6022
Mailing Address
P.O. Box 54197
Los Angeles, CA 90054-0197
VIA EDGAR
September 13, 2000
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Dear Madam/Sir:
Referring to this Registration Statement on behalf of FS Variable
Separate Account, (the "Account") having examined and being familiar with the
articles of incorporation and by-laws of First Sun America Life-Insurance
Company ("First Sun America"), the applicable resolutions relating to the
Account and other pertinent records and documents, I am of the opinion that:
1) First Sun America is a duly organized and existing stock life
insurance company under the laws of the State of New York.
2) The Account is a duly organized and existing separate account of
First Sun America
3) The annuity contracts being registered by the Registration
Statements will, upon sale thereof, be legally issued, fully
paid and nonassessable, and, to the extent that they are
construed to constitute debt securities, will be binding
obligations of First SunAmerica, except as enforceability may be
limited by bankruptcy, insolvency, reorganization or similar
laws affecting the rights of creditors generally,
I am licensed to practice only in the State of California, and the foregoing
opinions are limited to the laws of the State of California, the general
corporate law of the State of New York and federal law. I hereby consent to the
filing of this opinion with the Securities and Exchange Commission in connection
with the Registration Statements on Form N-4 on behalf of the Account.
Very truly yours,
/s/ Christine A. Nixon
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Christine S. Nixon
