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John Hancock Life Insurance Company
Law Sector
John Hancock Place
Post Office Box 111
Boston, Massachusetts 02117-0111

Ronald J. Bocage
Vice President and Counsel

December 21, 2001

Board of Directors
John Hancock Life Insurance Company

     Re:  John Hancock Life Insurance Company
          Registration Statement on Form S-6
          -----------------------------------

Dear Directors:

     In my capacity as Counsel of John Hancock Life Insurance Company (the
"Company"), I have represented the Company in connection with its development of
certain life products of a type which contemplates variable benefits. I have
participated in the preparation of the Registration Statement on Form S-6 filed
by the Company with the Securities and Exchange Commission under the Securities
Act of 1933, as amended, for the registration of interests in flexible premium
variable life contracts to be issued by the Company (the "Registration
Statement").

     I have reviewed the Articles and By-laws of the Company and such corporate
records and other documents and such laws as I consider necessary and
appropriate as a basis for the opinion hereinafter expressed. Based on my review
of such documents and laws, I am of the following opinion: the Company is a
corporation duly organized and validly existing under the laws of the
Commonwealth of Massachusetts and the interests in the flexible premium variable
life contracts, when issued as contemplated in the Registration Statement, will
be legal and binding obligations of the Company in accordance with the terms of
the aforesaid contracts.

     I hereby consent to the filing of my opinion as an exhibit to the
Registration Statement. I do not admit that I am in the category of persons
whose consent is required under section 7 of the Securities Act of 1933 or the
rules and regulations of the Securities and Exchange Commission thereunder.

                                        Very truly yours,

                                        /s/ RONALD J. BOCAGE
                                        -------------------------------
                                        Ronald J. Bocage, Esq.
                                        Vice President and Counsel