EX-99 11 ex99b9opinion75962pea54.htm EXHIBIT 99-B.9 OPINION AND CONSENT ex99b9opinion75962pea54.htm -- Converted by SEC Publisher, created by BCL Technologies Inc., for SEC Filing

                                                                                    Exhibit 99-B.9
                                                                    Opinion and Consent of Counsel

ING LOGO
AMERICAS
US Legal Services

Michael A. Pignatella
Counsel
Tel: 860.580.2831 | Fax: 860.580.4934
Email: michael.pignatella@us.ing.com

April 9, 2009

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attention: Filing Desk

Re: ING Life Insurance and Annuity Company and its Variable Annuity Account C
Post-Effective Amendment No. 54 to Registration Statement on Form N-4
Prospectus Title: Opportunity Plus – Multiple Option Group Variable Annuity Contracts
File Nos.: 033-75962* and 811-02513

Dear Sir or Madam:

The undersigned serves as counsel to ING Life Insurance and Annuity Company, a Connecticut life
insurance company (the “Company”). It is my understanding that the Company, as depositor, has
registered an indefinite amount of securities (the “Securities”) under the Securities Act of 1933 (the
“Securities Act”) as provided in Rule 24f-2 under the Investment Company Act of 1940 (the
“Investment Company Act”).

In connection with this opinion, I have reviewed the N-4 Registration Statement (the “Registration
Statement”), as amended to the date hereof, and this Post-Effective Amendment No. 54. I have also
examined originals or copies, certified or otherwise identified to my satisfaction, of such documents,
trust records and other instruments I have deemed necessary or appropriate for the purpose of
rendering this opinion. For purposes of such examination, I have assumed the genuineness of all
signatures on original documents and the conformity to the original of all copies.

I am admitted to practice law in Connecticut, and do not purport to be an expert on the laws of any
other state. My opinion herein as to any other law is based upon a limited inquiry thereof which I have
deemed appropriate under the circumstances.

Based upon the foregoing, and, assuming the Securities are sold in accordance with the provisions of
the prospectus, I am of the opinion that the Securities being registered will be legally issued and will
represent binding obligations of the Company.

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

Sincerely,

/s/ Michael A. Pignatella

Michael A. Pignatella

*      Pursuant to Rule 429(a) under the Securities Act of 1933, Registrant has included a combined prospectus
under this Registration Statement which includes all the information which would currently be required in a
prospectus relating to the securities covered by the following earlier Registration Statement: 033-75978.
 

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One Orange Way, C1S
Windsor, CT 06095-4774

 

ING North America Insurance Corporation