Exhibit 3

                                                                  April 25, 2002


The Prudential Insurance Company of America
Prudential Plaza
Newark, New Jersey 07102-3777

Gentlemen:

In my  capacity as Chief  Counsel,  Variable  Products,  Law  Department  of The
Prudential  Insurance  Company of America  ("Prudential"),  I have  reviewed the
establishment on August 11, 1987 of The Prudential Variable  Appreciable Account
(the "Account") by the Finance Committee of the Board of Directors of Prudential
as a separate  account for assets  applicable to certain variable life insurance
contracts,  pursuant  to the  provisions  of  Section  17B:28-7  of the  Revised
Statutes of New Jersey.  I am responsible  for oversight of the  preparation and
review  of the  Registration  Statements  on Form  S-6,  as  amended,  filed  by
Prudential with the Securities and Exchange  Commission  (Registration  Numbers:
33-20000,  333-64957,  and 33-61079)  under the  Securities  Act of 1933 for the
registration of certain variable life insurance contracts issued with respect to
the Account.

I am of the following opinion:

     1.   Prudential is a corporation duly organized under the laws of the State
          of New Jersey 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 New Jersey
          law.

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

     4.   The  variable   life   insurance   contracts  are  legal  and  binding
          obligations of Prudential, 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/
------------------------------------------------
Clifford E. Kirsch