EXHIBIT 2(a)

American
         General
         FINANCIAL GROUP
2929 Allen Parkway (A40-04), Houston, Texas 77019
                                                 Pauletta P. Cohn
                                                 Deputy General Counsel
                                                 Direct Line (713) 831-1230
                                                 FAX (713) 620-3878
                                                 E-mail: pauletta_cohn@agfg.com

                                October 26, 2001


The United States Life Insurance Company
  in the City of New York
390 Park Avenue, 5/th/ Floor
New York, New York 10022-4684

Dear Ladies and Gentlemen:

As Deputy General Counsel of American General Life Companies, I have acted as
counsel to The United States Life Insurance Company in the City of New York (the
"Company") in connection with the filing of Pre-Effective Amendment No. 1 to the
Registration Statement on Form S-6, File Nos. 333-57062 and 811-09359
("Registration Statement"), for the Company's Separate Account USL VL-R
("Separate Account USL VL-R") with the Securities and Exchange Commission. The
Registration Statement relates to the proposed issuance by the Company of
Platinum InvestorSM Survivor (Policy Form No. 99206N) last survivor flexible
premium variable life insurance policies (the "Policies"). Net premiums received
under the Policies are allocated by the Company to Separate Account USL VL-R to
the extent directed by owners of the Policies. Net premiums under other policies
that may be issued by the Company may also be allocated to Separate Account USL
VL-R. The Policies are designed to provide retirement protection and are to be
offered in the manner described in the prospectus and the prospectus supplements
included in the Registration Statement. The Policies will be sold only in
jurisdictions authorizing such sales.

In connection with rendering this opinion, I have examined and am familiar with
originals or copies, certified or otherwise identified to my satisfaction, of
the corporate records of the Company and all such other documents as I have
deemed necessary or appropriate as a basis for the opinion expressed herein and
have assumed that prior to the issuance or sale of any Policies, the
Registration Statement, as finally amended, will be effective.

Based on and subject to the foregoing and the limitations, qualifications,
exceptions and assumptions set forth herein, I am of the opinion that:

1.   The Company is a corporation duly organized and validly existing under the
     laws of the State of New York.

                        American General Life Companies
                     2929 Allen Parkway . Houston, TX 77019



The United States Life Insurance Company
  in the City of New York
October 26, 2001
Page 2


2.  Separate Account USL VL-R was duly established and is maintained by the
    Company pursuant to the laws of the State of New York, under which income,
    gains and losses, whether or not realized, from assets allocated to Separate
    Account USL VL-R, are, in accordance with the Policies, credited to or
    charged against Separate Account USL VL-R without regard to other income,
    gains or losses of the Company.

3.  Assets allocated to Separate Account USL VL-R will be owned by the Company.
    The Company is not a trustee with respect thereto. The Policies provide that
    the portion of the assets of Separate Account USL VL-R equal to the reserves
    and other Policy liabilities with respect to Separate Account USL VL-R will
    not be chargeable with liabilities arising out of any other business the
    Company may conduct. The Company reserves the right to transfer assets of
    Separate Account USL VL-R in excess of such reserves and other Policy
    liabilities to the general account of the Company.

4.  When issued and sold as described above, the Policies (including any units
    of Separate Account USL VL-R duly credited thereunder) will be duly
    authorized and will constitute validly issued and binding obligations of the
    Company in accordance with their terms.

I am admitted to the bar in the State of Texas, and I do not express any opinion
as to the laws of any other jurisprudence.

This opinion is being furnished in accordance with the requirements of Item
601(b)(5), Regulation S-K of the Securities Act of 1933 and I hereby consent to
the use of this opinion as an exhibit to the Registration Statement.


                                        Sincerely,



                                        /s/ PAULETTA P. COHN
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