Exhibit 3

                                                              September 12, 2002

Pruco Life Insurance Company
213 Washington Street
Newark, New Jersey 07102-2992

Gentlemen:

In my capacity as Chief Legal Officer and Assistant Secretary of Pruco Life
Insurance Company ("Pruco Life"), I have reviewed the establishment on April 17,
1989 of Pruco Life Variable Universal Account (the "Account") by the Executive
Committee of the Board of Directors of Pruco Life as a separate account for
assets applicable to certain variable life insurance contracts, pursuant to the
provisions of Section 20-651 of the Arizona Insurance Code. I am responsible for
oversight of the preparation and review of the Registration Statement on Form
S-6, as amended, filed by Pruco Life with the Securities and Exchange Commission
(Registration Numbers: 333-85115, 333-94117, and 333-49332) under the Securities
Act of 1933 for the registration of certain variable universal life insurance
contracts issued with respect to the Account.

I am of the following opinion:

      (1)   Pruco Life was duly organized under the laws of Arizona and is a
            validly existing corporation.

      (2)   The Account has been duly created and is validly existing as a
            separate account pursuant to the aforesaid provisions of Arizona
            law.

      (3)   The portion of the assets held in the Account equal to the reserve
            and other liabilities for variable benefits under the variable
            universal life insurance contracts is not chargeable with
            liabilities arising out of any other business Pruco Life may
            conduct.

      (4)   The variable universal life insurance contracts are legal and
            binding obligations of Pruco Life in accordance with their terms.

In arriving at the foregoing opinion, I have made such examination of law and
examined such records and other documents as I judged to be necessary or
appropriate.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Very truly yours,


/s/
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Clifford E. Kirsch