STEPHEN E. ROTH
   DIRECT LINE: 202.383.0158
   Internet: sroth@sablaw.com

                                  March 4, 2003

VIA EDGAR

U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

     Re:  MONY America Variable Account L
          File No. 333-103552
          Accession No. 0001021408-03-003632
          Withdrawal of Registration Statement Pursuant to Rule 477

Commissioners:

         On behalf of MONY America Variable Account L (the "Variable Account")
of MONY Life Insurance Company of America ("MLOA"), we hereby request that the
above-referenced registration statement under the Securities Act of 1933 (Form
N-6, File No. 333-103552) be withdrawn, pursuant to Rule 477 under that Act.

         On March 3, 2003, the registration statement was inadvertently
submitted and accepted via EDGAR as an initial registration statement on N-6,
the incorrect filing type. On March 3, 2003, the registration statement was
re-submitted and accepted via EDGAR as a 485APOS, the correct filing type (File
No. 333-06071). The initial registration statement on N-6 (File No. 333-103552)
never became effective and no securities were sold in connection with the
registration statement.

         It should be noted that the Variable Account is a registered unit
investment trust under the Investment Company Act of 1940 (the "1940 Act") (File
No. 811-04234). The Variable Account is the funding vehicle for different
classes of variable life insurance policies issued by MLOA, registered
separately under the Securities Act of 1933. Therefore, the Variable Account
will maintain its registered status under the 1940 Act.



U.S. Securities and Exchange Commission
March 4, 2003
Page 2 of 2

         If there are any questions or comments concerning this request, please
call me at (202) 383-0158 or Pamela Ellis at (202) 383-0566.

                                       Sincerely,



                                       Stephen E. Roth

cc:  Ellen Sazzman, Esq.
     Haroula Ballas, Esq.
     Pamela K. Ellis, Esq.