Exhibit 9
Written Opinion of Edwin L. Kerr, Esq.
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November 20, 2000
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
Re: PHL Variable Accumulation Account
PHL Variable Insurance Company
Post-Effective Amendment No. 2 to Form N-4
File Nos. 333-78761 and 811-8914
Dear Sirs:
As Counsel to the depositor, I have participated in the development of and am
familiar with the variable annuity, Phoenix Retirement Planner's Edge, which is
the subject of the above-captioned registration statement on Form N-4.
In connection with this opinion, I have reviewed the contracts, the registration
statement, the charter and by-laws of the company, relevant proceedings of the
Board of Directors, and the provisions of New York insurance law relevant to the
issuance of the Contracts.
Based upon this review, I am of the opinion that the contracts, when issued,
will be validly issued, and will constitute a legal and binding obligation of
PHL Variable Insurance Company.
Very truly yours,
/s/ Edwin L. Kerr
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Edwin L. Kerr, Counsel
PHL Variable Insurance Company
