[LOGO]
                                                                    THE HARTFORD



March 3, 2005




To:  Board of Directors of Hartford Life Insurance Company

RE:    Enforceability of Funding Agreements Issued to Certain Trusts


Ladies and Gentlemen:

I am Counsel to Hartford Life Insurance Company ("Hartford Life"), a Connecticut
life insurance corporation.

I am furnishing this opinion in connection with the issuance by Hartford Life of
the funding agreements listed below (each a "Contract") to the trusts (each a
"Trust") listed below on or about the date of this letter:

    CONTRACT                       CONTRACTHOLDER
    --------                       --------------

    Funding Agreement FA-405031    Hartford Life Global Funding Trust 2005 - 031
    Funding Agreement FA-405032    Hartford Life Global Funding Trust 2005 - 032
    Funding Agreement FA-405033    Hartford Life Global Funding Trust 2005 - 033


In each instance the Trust was established pursuant to the Hartford Life Global
Funding note issuance program (the "Program") described in that certain
registration statement on Form S-3 (File No. 333-112244) filed on January 27,
2004 (the "Registration Statement") with the Securities and Exchange Commission
(the "SEC") under the Securities Act of 1933, as amended (the "Act"), as amended
by Amendment No. 1 thereto, filed with the SEC on March 16, 2004; by Amendment
No. 2 thereto, filed with the SEC on May 4, 2004; and by Amendment No. 3
thereto, filed with the SEC on July 27, 2004. The Registration Statement
describes (i) the registration and public offering of up to $2 billion, in the
aggregate principal amount of notes (the "Notes") to be issued by a series of
trusts and (ii) the registration of up to $2,000,000,000, or the equivalent
amount in one or more foreign or composite currencies, aggregate principal
amount of Hartford Life's funding agreements (each, a "Contract") to be sold to
the trusts described below in connection with the issuance and sale of the
Notes.

Each of the Trusts is intended to be a trust described in the prospectus
(including the prospectus supplement relating to IncomeNotes(sm)), both dated
September 7, 2004, and included in the Registration Statement (together, the
"Prospectus"). Once duly formed, each Trust is authorized to issue no more than
a single series of Notes and to take certain other actions necessary or
appropriate to such issuance. The proceeds from the sale of each series of Notes
are to be used by each Trust to purchase separately from Hartford Life a funding
agreement, such as the Contracts listed above. As described in the Prospectus,
the Notes issued by each Trust are to be secured by the assignment to an
indenture trustee of its Contract and all proceeds from its Contract.

In connection with the foregoing, I, or persons under my supervision, have
examined an original or copies certified to my satisfaction as being a true copy
of the certificate of incorporation and bylaws of Hartford Life, and have
reviewed such other corporate records, instruments and other documents as deemed
necessary or appropriate in order to render the opinions set forth herein. I, or
persons under my supervision, have also reviewed, in unexecuted form, each of
the Contracts.

In the examination of various documents, instruments and records, including
without limitation any referred to in this opinion letter, and in connection
with the opinions herein expressed, I have assumed the competency of all
individual signatories, the genuineness of all signatures, submitted as
certified, photostatic or electronic copies, and the authenticity of the
originals of such latter documents.






Board of Directors of Hartford Life Insurance Company
March 3, 2005
Page Two



Based upon and subject to the foregoing, I am of the opinion that, as of the
date of this letter:

        (a)       Hartford Life is a  Connecticut  domiciled  insurance  company
                  duly  organized,  validly  existing and in good standing under
                  the  laws  of  Connecticut  as a  corporation  formed  for the
                  purposes  of  conducting  the  business  of a  life  insurance
                  company.  Hartford Life has the necessary  corporate authority
                  to  enter  into  each  of the  Contracts  and to  perform  its
                  respective obligations thereunder.

        (b)       Hartford  Life  has  obtained  licenses  from  the  states  of
                  Connecticut  and Delaware,  which  authorize  Hartford Life to
                  conduct  life  insurance   business  and  to  issue  insurance
                  contracts  (including  each of the Contracts) in those states.
                  Hartford  Life has all  necessary  authority to execute and to
                  issue such Contracts under applicable Connecticut and Delaware
                  insurance laws and regulations and orders and  interpretations
                  of the  Connecticut  Insurance  Department  and  the  Delaware
                  Insurance Department.

        (c)       The issuance of each of the Contracts has been approved by all
                  necessary  corporate  action on the part of Hartford Life; and
                  each  Contract   constitutes  the  legal,  valid  and  binding
                  obligation of Hartford Life,  enforceable  in accordance  with
                  its terms, except to the extent enforceability  thereof may be
                  limited by (i) bankruptcy, insolvency, fraudulent conveyances,
                  fraudulent transfers,  reorganization,  or moratorium or other
                  similar  laws  now  or  hereafter  in  effect  relating  to or
                  effecting the  enforcement  of  creditors'  rights or remedies
                  generally and (ii) general principles of equity (regardless of
                  whether such  enforcement  is  considered  in a proceeding  in
                  equity  or at law),  including  the  discretion  of the  court
                  before which any proceeding  may be brought,  concepts of good
                  faith, reasonableness and fair dealing.


I consent  to the  filing  of this  opinion  with the  Securities  and  Exchange
Commission as an exhibit to the Current  Report of Hartford Life on Form 8-K and
to the use of my name under the heading "Legal Matters" in the Prospectus and to
the  incorporation  by  reference of this opinion and consent as exhibits to the
Registration  Statement  filed in accordance  with Rule 462(b) under the Act. In
giving the  foregoing  consents,  I do not thereby  admit that I come within the
category of persons, whose consent is required under Section 7 of the Securities
Act of 1933, as amended,  or the rules and  regulations  of the  Securities  and
Exchange Commission thereunder.

Very truly yours,

/s/ Jonathan Mercier


Jonathan Mercier, Counsel
Hartford Life Insurance Company