Exhibit 8
SIDLEY AUSTIN LLP BEIJING GENEVA SAN FRANCISCO
[GRAPHIC OMITTED] ONE SOUTH DEARBORN BRUSSELS HONG KONG SHANGHAI
CHICAGO, IL 60603 CHICAGO LONDON SINGAPORE
312 853 7000 DALLAS LOS ANGELES TOKYO
312 853 7036 FAX NEW YORK WASHINGTON D.C.
FOUNDED 1866
February 23, 2006
Hartford Life Insurance Company
200 Hopmeadow Street
Simsbury, Connecticut 06089
Re: Hartford Life Global Funding Trust 2006-017 Secured
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Medium-Term Notes
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Ladies and Gentlemen:
This opinion letter is delivered to you in connection with the issuance
by Hartford Life Global Funding Trust 2006-017 (the "Trust") of $250,000,000
aggregate principal amount of the Trust's 5.20% Secured Medium-Term Notes due
2011 (the "Notes") related to funding agreement No. FA-406017 (the "Funding
Agreement") executed by Hartford Life Insurance Company, a Connecticut life
insurance company ("Hartford Life"). The Trust was formed on February 15, 2006
(the "Formation Date") and the Notes will be issued on February 23, 2006 (the
"Issuance Date").
We have acted as counsel to Bear, Stearns & Co. Inc. and each other
agent under the Hartford Life Global Funding Trusts Program (each, an "Agent")
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 No.
333-123441) filed with the Commission on March 18, 2005, as amended by Amendment
No. 1 filed with the Commission on April 12, 2005 and Post-Effective Amendment
No. 1 filed with the Commission on December 13, 2005 (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 secured
medium-term notes to be issued by the trusts (the "Institutional Prospectus
Supplement"). The Registration Statement provides for: (i) the registration of
up to $5,000,000,000, 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 $5,000,000,000, 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, the Institutional Prospectus Supplement and the
pricing supplement related to the Notes, dated as of the Formation Date, (ii)
the trust agreement, dated as of the Formation Date (the "Trust Agreement"),
between Wilmington Trust Company, as trustee, and AMACAR
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[GRAPHIC OMITTED] HARTFORD LIFE INSURANCE COMPANY
FEBRUARY 23, 2006
Page 2 CHICAGO
Pacific Corp., as trust beneficial owner, which adopts and incorporates the
standard trust terms dated March 18, 2005, (iii) the indenture, dated as of the
Issuance Date (the "Indenture"), between JPMorgan Chase Bank, N.A., as indenture
trustee, and the Trust, which adopts and incorporates the standard indenture
terms dated March 18, 2005, (iv) the distribution agreement, dated as of the
Formation Date (the "Distribution Agreement"), between Hartford Life, Barclays
Capital Inc. and the Trust, which adopts and incorporates the standard
distribution agreement terms dated March 18, 2005, (v) the omnibus instrument,
dated as of the Formation Date, which includes the Trust Agreement, Indenture
and Distribution Agreement executed in connection with the creation of the Trust
and the issuance by the Trust of the Notes, (vi) the closing instrument, dated
as of the Issuance Date, related to the Trust, (vii) the Notes, (viii) the
Funding Agreement and (ix) such other records, documents, certificates or other
instruments as in our judgment were necessary or appropriate to enable us to
render the opinion expressed below. 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 also
assumed that the transactions described in the Registration Statement are
performed in the manner described therein.
Based on the foregoing, and subject to the limitations, qualifications
and assumptions set forth herein, the discussion set forth in the Institutional
Prospectus Supplement under the heading "Material United States Federal Income
Tax Considerations," to the extent describing matters of United States federal
income tax law or legal conclusions with respect thereto, is our opinion.
In rendering the opinion set forth above, we have considered the
applicable provisions of the Internal Revenue Code of 1986, as amended (the
"Code"), regulations promulgated thereunder by the United States Treasury
Department (the "Regulations"), pertinent judicial authorities, rulings and
other administrative interpretations of the Internal Revenue Service and such
other authorities as we have considered relevant. It should be noted that the
Code, the Regulations and such judicial authorities, rulings, and administrative
interpretations and other authorities are subject to change at any time and, in
some circumstances, with retroactive effect; and any such change could affect
the opinion stated herein.
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 facts or 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 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 LLP