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                                                                 Exhibit (k)(ii)

April 26, 2004

Metropolitan Life Separate Account UL
Metropolitan Life Insurance Company
One Madison Avenue
New York, NY 10010

Ladies and Gentlemen:

         In my capacity as Associate General Counsel of Metropolitan Life
Insurance Company (the "Company"), I am rendering the following opinion in
connection with the filing with the Securities and Exchange Commission of an
amendment to the registration statement on Form N-6 (File No. 333-40161) under
the Securities Act of 1933. This Amendment to the Registration Statement is
being filed with respect to individual variable additional insurance options
issued by Metropolitan Life Separate Account UL (the "Account"). It is my
professional opinion that:

     1.   The Account is a separate investment account of the Company and is
          validly existing pursuant to the laws of the State of New York.

     2.   The Equity Options, when issued in accordance with the prospectus
          contained in the amendment to the Registration Statement and in
          compliance with applicable local law, are and will be legal and
          binding obligations of the Company in accordance with their terms; and

     3.   Assets attributable to reserves and other contract liabilities and
          held in the Account will not be chargeable with liabilities arising
          out of any other business the Company may conduct.

         In forming this opinion, I have made such examination of law and
  examined such records and other documents as in my judgment are necessary and
  appropriate.

         I hereby consent to the filing of this opinion letter as an exhibit to
  the Registration Statement and to the use of my name under the caption "Legal
  Matters" in the Statement of Additional Information contained in the amendment
  to the Registration Statement.

                                                Very truly yours,

                                                /s/ Marie C. Swift

                                                Marie C. Swift, Esq.
                                                Associate General Counsel