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Re:			Jackson National Life Insurance Company of New York (“Jackson of New York”) JNLNY Separate Account I File Nos. 333-226898 and 811-08401

You have requested our Opinion of Counsel in connection with the filing with the Securities and Exchange Commission of Post-Effective Amendment No. 12 to a Registration Statement on Form N-4 for the Flexible Premium Variable Deferred Annuity Contracts (the "Contracts") to be issued by Jackson of New York and its separate account, JNLNY Separate Account I. Legal services in connection with this opinion are provided pursuant to the Administrative Services Agreement between Jackson National Life Insurance Company and Jackson of New York.

We have made such examination of the law and have examined such records and documents as in our judgment are necessary or appropriate to enable us to render the opinions expressed below.


1.			JNLNY Separate Account I is a Unit Investment Trust as that term is defined in Section 4(2) of the Investment Company Act of 1940 (the "Act"), and is currently registered with the Securities and Exchange Commission, pursuant to Section 8(a) of the Act.
2.			Upon the acceptance of premium payments made by an Owner pursuant to a Contract issued in accordance with the Prospectus contained in the Registration Statement and upon compliance with applicable law, such an Owner will have a legally issued, fully paid, non-assessable contractual interest under such Contract.

You may use this opinion letter, or a copy thereof, as an exhibit to Post-Effective Amendment No. 12 to the Registration Statement.

Jackson® is the marketing name for Jackson National Life Insurance Company® (Home Office: Lansing, Michigan) and Jackson National Life Insurance Company of New York® (Home Office: Purchase, New York).