DODIE KENT
                                                      Vice President and Counsel
                                                                  (212) 314-3970
                                                             Fax: (212) 707-1791
[EQUITABLE - MEMBER OF THE GLOBAL AXA GROUP - LOGO]
                                                                  LAW DEPARTMENT


                                               April 27, 2004

VIA EDGAR
---------


The Equitable Life Assurance Society of the United States
1290 Avenue of the Americas
New York, New York 10104

Dear Sirs:

        This opinion is furnished in connection with the Registration Statement
on Form N-3 (Registration Statement) being filed by The Equitable Life Assurance
Society of the United States (Equitable) under the Securities Act of 1933, as
amended (Act), to register separate account units of interest (Units) under
group annuity contracts (Contracts).  The Contracts are designed to provide an
investment program for retirement plans and trusts of partnerships and sole
proprietors, among other entities, under Equitable's Retirement Investment
Account program.  Such plans and trusts are qualified under Section 401 of the
Internal Revenue Code of 1986, as amended.  The securities being registered are
to be offered in the manner described in the Registration Statement.

        I have examined all such corporate records of Equitable and such other
documents and such laws as I consider appropriate as a basis for the opinion
hereinafter expressed.  On the basis of such examination, it is my opinion that:

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

        2. The Separate Accounts have been duly created pursuant to the
provisions of the New York Insurance Law.

        3. The assets of the Separate Accounts are owned by Equitable; Equitable
is not a trustee with respect thereto.  Under New York law, the income, gains
and losses, whether or not realized, from assets allocated to a Separate Account
must be credited to or charged against such Separate Account, without regard to
the other income, gains or losses of Equitable.

        4. The Contracts provide that the portion of the assets of the Separate
Accounts equal to the reserves and other contract liabilities with respect to
the Separate Account shall not be chargeable with liabilities arising out of any
other business Equitable may conduct.

        5. The Contracts and the Units issued thereunder have been duly
authorized; and the Contracts (including the Units duly issued thereunder)
constitute validly issued and binding obligations of Equitable in accordance
with their terms.

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


                                                        Very truly yours,


                                                    /s/ Dodie Kent
                                                        ------------------------
                                                        Dodie Kent