ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
                          LAW AND REGULATION DEPARTMENT

                             3100 Sanders Road, J5B

                           Northbrook, Illinois 60062

                         Direct Dial Number 847-402-2400

                             Facsimile 847-402-4371

Michael J. Velotta
 Vice President, Secretary

   and General Counsel

                                January 28, 2000

TO:               ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK
                  FARMINGVILLE, NEW YORK  11738-9075

FROM:             MICHAEL J. VELOTTA
                  VICE PRESIDENT, SECRETARY AND GENERAL COUNSEL

RE:               FORM S-3 REGISTRATION STATEMENT
                  UNDER THE SECURITIES ACT OF 1933

         With  reference  to the  Registration  Statement  on Form S-3  filed by
Allstate Life Insurance Company of New York (the "Company"), as registrant, with
the Securities and Exchange  Commission  covering the Flexible  Premium Deferred
Annuity  Contracts,  I have  examined  such  documents  and  such  law as I have
considered necessary and appropriate,  and on the basis of such examination,  it
is my opinion that:

1.       The Company is duly  organized and existing under the laws of the State
         of New York and has been duly authorized to do business by the Director
         of Insurance of the State of New York.

2.       The  securities  registered by the above  Registration  Statement  when
         issued will be valid, legal and binding obligations of the Company.

         I hereby  consent  to the  filing of this  opinion as an exhibit to the
above  referenced  Registration  Statement  and to the use of my name  under the
caption  "Legal   Matters"  in  the  Prospectus   constituting  a  part  of  the
Registration Statement.

Sincerely,


/s/MICHAEL J. VELOTTA
- -------------------------
Michael J. Velotta
Vice President, Secretary and

  General Counsel