EXHIBIT 8 OPINION AND CONSENT OF EDWIN L. KERR, ESQ. November 3, 1997 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 RE: PHOENIX LIFE AND ANNUITY VARIABLE UNIVERSAL LIFE ACCOUNT REGISTRATION STATEMENT NO. 33-12989 Dear Sirs: As Counsel to the depositor, I am familiar with the flexible premium variable life insurance policies (the "Policies") which are the subject of the above-captioned Registration Statement on Form S-6. In connection with this opinion, I have reviewed the Policies, the Registration Statement, the Charter and By-Laws of the Company, relevant proceedings of the Board of Directors, and the provisions of Connecticut insurance law relevant to the issuance of the Policies. Based upon this review, I am of the opinion that each of the Policies, when issued, will have been validly issued, and will constitute a legal and binding obligation of Phoenix Life and Annuity Company. I further consent to the use of this opinion as an exhibit to the above-captioned Registration Statement and to my being named under "Legal Matters" therein. Very truly yours, /s/ Edwin L. Kerr Edwin L. Kerr, Counsel Phoenix Home Life Mutual Insurance Company