EX-99.11 OPIN COUNSL 3 ex99b9opinion75980.htm 485B OPINION OF COUNSEL 75980 2010 ex99b9opinion75980.htm - Generated by SEC Publisher for SEC Filing
Ex 24(b)(9)
Opinion and Consent of Counsel
 
 
ING LOGO   
AMERICAS   
US Legal Services   
 
 
Michael A. Pignatella   
Counsel   
(860) 580-2831   
Fax: (860) 580-4934   
 
 
April 21, 2010   
 
 
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. 25 to Registration Statement on Form N-4 
Prospectus Title: MAP II Group Installment Variable Annuity Contracts for HR 10 Plans 
             File Nos.: 033-75980* 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 or those for whom I have supervisory responsibility, have reviewed the 
N-4 Registration Statement, as amended to the date hereof, and this Post-Effective Amendment No. 25. 
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. 
 
 
* 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 Registration Statement No. 33-75984. 
 
 
 
Windsor Site  ING North America Insurance Corporation 
One Orange Way, C1S   
Windsor, CT 06095-4774   



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