Exhibit 5.1 Jones, Day, Reavis & Pogue 77 West Wacker Chicago, Illinois 60601-1692 Telephone: 312-782-3939 Facsimile: 312-782-8585 February 12, 1997 Dignity Partners, Inc. 1700 Montgomery Street, Suite 250 San Francisco, California 94111 Re: Stock Option Plan for Non-Employee Directors -------------------------------------------- Ladies and Gentlemen: We have acted as counsel for Dignity Partners, Inc., a Delaware corporation (the "Company"), in connection with the adoption of the Dignity Partners, Inc. Stock Option Plan for Non-Employee Directors (the "Director Plan"). We have examined such documents, records and matters of law as we have deemed necessary for purposes of this opinion, and based thereupon we are of the opinion that the shares of Common Stock, par value $.01 per share, that may be issued or transferred and sold pursuant to the Director Plan will be, when issued or transferred and sold in accordance with the Director Plan and upon the Company's receipt of legal consideration therefor, duly authorized, validly issued, fully paid and nonassessable. We hereby consent to the filing of this opinion as Exhibit 5.1 to the Registration Statement on Form S-8 filed by the Company to effect registration under the Securities Act of 1933 of the shares to be issued and sold pursuant to the Director Plan. Very truly yours, /s/JONES, DAY, REAVIS & POGUE