10 State House Square, SH11
Hartford, CT 06103-3602
Michael Gioffre
Counsel
Aetna Generation Portfolios, Inc.
August 1, 2000 (860) 275-3252
Fax: (860) 275-2158
U.S. Secuities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Filing Desk
Re: Aetna Generation Portfolios, Inc.
Post-Effective Amendment No. 11 to
Registration Statement on Form N-1A
(File No. 33-88334 and 811-8934)
Dear Sir or Madam:
The undersigned serves as counsel to Aetna Generation Portfolios, Inc., a
Maryland corporation (the "Company"). It is my understanding that the Company
has registered an indefinite number of shares of beneficial interest under the
Securities Act of 1933 (the "1933 Act") pursuant to Rule 24f-2 under the
Investment Company Act of 1940 (the "1940 Act").
Insofar as it relates or pertains to the Company, I have reviewed the prospectus
and the Company's Registration Statement on Form N-1A, as amended to the date
hereof, filed with the Securities and Exchange Commission under the 1933 Act and
the 1940 Act, pursuant to which the Shares will be sold (the "Registration
Statement"). I have also examined originals or copies, certified or otherwise
identified to my satisfaction, of such documents and other instruments I have
deemed necessary or appropriate for the purpose of 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.
Based upon the foregoing, and assuming the securities are issued and sold in
accordance with the provisions of the Company's Articles of Incorporation and
the Registration Statement, I am of the opinion that the securities will when
sold be legally issued, fully paid and nonassessable.
I consent to the filing of this opinion as an exhibit to the Registration
Statement.
Sincerely,
/s/ Michael Gioffre
Michael Gioffre
Counsel
