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                                 March 31, 2005



Hartford Life Insurance Company
200 Hopmeadow Street
Simsbury, Connecticut  06089

                  Re:   HARTFORD LIFE GLOBAL FUNDING TRUSTS 2005-040, 2005-041,
                        2005-042 AND 2005-043 INCOMENOTES(SM)

Ladies and Gentlemen:

     This opinion letter is delivered to you in connection with:

          1.   the issuance by Hartford Life Global  Funding Trust 2005-040 (the
               "2005-040 Trust") of $4,946,000 aggregate principal amount of the
               2005-040  Trust's  Floating  Rate  IncomeNotes(sm)  due 2010 (the
               "2005-040 Notes") related to funding agreement No. FA-405040 (the
               "2005-040 Funding Agreement") executed by Hartford Life Insurance
               Company, a Connecticut life insurance company ("Hartford Life");

          2.   the issuance by Hartford Life Global  Funding Trust 2005-041 (the
               "2005-041  Trust") of $11,868,000  aggregate  principal amount of
               the 2005-041 Trust's 5.00% Callable IncomeNotes(sm) due 2012 (the
               "2005-041 Notes") related to funding agreement No. FA-405041 (the
               "2005-041 Funding Agreement") executed by Hartford Life;

          3.   the issuance by Hartford Life Global  Funding Trust 2005-042 (the
               "2005-042 Trust") of $661,000  aggregate  principal amount of the
               2005-042  Trust's  Floating  Rate  IncomeNotes(sm)  due 2015 (the
               "2005-042 Notes") related to funding agreement No. FA-405042 (the
               "2005-042 Funding Agreement") executed by Hartford Life; and



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SIDLEY AUSTIN BROWN & WOOD LLP                                          NEW YORK

Hartford Life Insurance Company
March 31, 2005
Page 2


          4.   the issuance by Hartford Life Global  Funding Trust 2005-043 (the
               "2005-043 Trust") of $2,808,000 aggregate principal amount of the
               2005-043  Trust's 5.50%  Callable  IncomeNotes(sm)  due 2020 (the
               "2005-043 Notes") related to funding agreement No. FA-405043 (the
               "2005-043 Funding Agreement") executed by Hartford Life.

The 2005-040  Trust,  the 2005-041  Trust,  the 2005-042  Trust and the 2005-043
Trust are referred to collectively  herein as the "Trusts";  the 2005-040 Notes,
the 2005-041  Notes,  the 2005-042  Notes and the 2005-043 Notes are referred to
collectively  herein as the "Notes";  and the 2005-040  Funding  Agreement,  the
2005-041  Funding  Agreement,  the 2005-042  Funding  Agreement and the 2005-043
Funding   Agreement  are  referred  to  collectively   herein  as  the  "Funding
Agreements." The Trusts were formed on March 28, 2005 (the "Formation Date") and
the Notes will be issued on March 31, 2005 (the "Issuance Date").

         We have  acted as  special  counsel  to Bear,  Stearns & Co.  Inc.,  in
connection  with the  preparation  and filing with the  Securities  and Exchange
Commission (the "Commission")  under the Securities Act of 1933, as amended (the
"Act"),  by Hartford  Life, of a  Registration  Statement on Form S-3 (File Nos.
333-112244),  as amended by Amendment  No. 1 filed with the  Commission on March
16, 2004, Amendment No. 2 filed with the Commission on May 4, 2004 and Amendment
No. 3 filed with the Commission on July 27, 2004 (the "Registration Statement"),
including a prospectus (the "Prospectus") relating to secured notes to be issued
by newly formed  statutory trusts formed under the laws of the State of Delaware
and a prospectus  supplement  relating to Hartford  Life  IncomeNotes(sm)  to be
issued by the trusts (the  "Retail  Prospectus  Supplement").  The  Registration
Statement  provides for: (i) the  registration of up to  $2,000,000,000,  or the
equivalent amount in one or more foreign currencies,  aggregate principal amount
of  notes  to be  issued  by the  trusts  and  (ii)  the  registration  of up to
$2,000,000,000,  or the equivalent amount in one or more foreign currencies,  of
Hartford  Life's funding  agreements to be sold to the trusts in connection with
the sale of notes.

         In furnishing  this opinion,  we have  reviewed:  (i) the  Registration
Statement, the Prospectus and the Retail Prospectus Supplement,  and each of the
pricing  supplements related to the Notes, each such pricing supplement dated as
of the  Formation  Date,  (ii)  each of the  trust  agreements,  dated as of the
Formation Date (the "Trust  Agreements"),  between Wilmington Trust Company,  as
trustee,  and AMACAR Pacific Corp., as trust beneficial  owner,  which adopt and
incorporate  the  standard  trust terms dated July 23,  2004,  (iii) each of the
indentures,  dated as of the Issuance Date (the "Indentures"),  between JPMorgan
Chase Bank,  N.A.,  as  indenture  trustee  (the  "Indenture  Trustee")  and the
relevant Trust,  which adopt and incorporate the standard  indenture terms dated
July  23,  2004,  (iv)  each of the  distribution  agreements,  dated  as of the
Formation Date (the  "Distribution  Agreements"),  between  Hartford Life, Bear,
Stearns & Co. Inc.,  on behalf of itself and each of the other  agents,  and the
relevant Trust, which adopt and incorporate the standard distribution  agreement
terms dated July 23, 2004, (v) each of the omnibus instruments,  dated as of the
Formation  Date,  which  include the relevant Trust




SIDLEY AUSTIN BROWN & WOOD LLP                                          NEW YORK

Hartford Life Insurance Company
March 31, 2005
Page 3


Agreement,  Indenture and Distribution Agreement executed in connection with the
creation of the Trusts and the issuance by the Trusts of the Notes, (vi) each of
the closing instruments, dated as of the Issuance Date, related to each relevant
Trust, (vii) the Notes and (viii) each of the Funding Agreements.

         We have also reviewed the trust action of the Trusts in connection with
the issuance of the Notes,  and have examined,  and have relied as to matters of
fact  upon,  originals  or  copies  certified  or  otherwise  identified  to our
satisfaction, of such records, agreements,  documents, and other instruments and
such  certificates or comparable  documents of public  officials and of officers
and   representatives   of  the  Trust,   and  have  made  such  other   further
investigations  as we have  deemed  relevant  and  necessary  as a basis for the
opinions  hereinafter  set  forth.  In such  examination,  we have  assumed  the
authenticity of all documents  submitted to us as originals,  the genuineness of
all  signatures,  the legal  capacity of all natural  persons and the conformity
with the original  documents of any copies  submitted to us for our examination.
We have relied as to factual  matters  upon,  and have  assumed the accuracy of,
representations,  statements and certificates of or from public officials and of
or from  officers  and  representations  of all  persons  whom  we  have  deemed
appropriate.

         Based  upon  the  foregoing,  and  subject  to the  qualifications  and
limitations  stated  herein,  we are of the  opinion  that  upon the  execution,
issuance,  authentication  and delivery of the Notes, the relevant Notes will be
the valid and binding  obligations of the relevant  Trust,  enforceable  against
such Trust in accordance with their terms.

         The above opinions with regard to the  enforceability of the Notes: (i)
are  qualified  by  the  effects  of  bankruptcy,  insolvency,   reorganization,
moratorium or similar laws relating to or affecting  creditors' rights generally
and general  principles of equity  (regardless  of whether such  principles  are
considered  in a  proceeding  in equity or at law),  and (ii) are subject to the
further  qualification  that, to the extent that the Notes are  denominated in a
currency  other than  United  States  dollars,  a claim  thereunder  (or foreign
currency  judgment  in respect to such  claim)  would be  converted  into United
States dollars at a rate of exchange prevailing on a date determined pursuant to
applicable law.

         We express no opinion as to the laws of any jurisdiction other than the
laws of the State of New York, as currently in effect.  This opinion is rendered
as of the date  hereof  based  upon the facts and law in  existence  on the date
hereof.  We assume no obligation to update or supplement  this letter to reflect
any circumstances  which may hereafter come to our attention with respect to the
opinion and statements set forth above,  including any changes in applicable law
which may hereafter occur.

         We hereby  consent  to the  filing of this  letter as an exhibit to the
Current  Report  on Form  8-K  filed by  Hartford  Life in  connection  with the
issuance and sale of the Notes,  incorporated  by reference in the  Registration
Statement.  In giving such consent, we do not thereby concede that



SIDLEY AUSTIN BROWN & WOOD LLP                                          NEW YORK

Hartford Life Insurance Company
March 31, 2005
Page 4



we are within the category of persons whose consent is required  under Section 7
of the Act or the rules and regulations of the Commission thereunder.

                                       Very truly yours,

                                       /s/ Sidley Austin Brown & Wood LLP