Law Offices
Xxxxx, Xxxx & Xxxxx, L.L.P.
a registered limited liability partnership
including professional corporations
Xxx Xxxxx Xxxxx
Xxxxxxxxx, Xxxxx 00000
Galveston (000) 000-0000
Houston (000) 000-0000
Telecopier (000) 000-0000
April 26, 2007
Securities and Exchange Commission
000 Xxxxx Xxxxxx, X.X.
Judicial Plaza
Washington, D.C. 20549
RE: American National Variable Annuity Separate Account ("Separate Account") Post-Effective
Amendment No. 9 to Form N-4; File No. 333-33856; Opinion and Consent of
Counsel
Gentlemen:
We are counsel to American National Insurance Company ("ANICO"), the depositor of the Separate
Account. As such, we participated in the formation of the Separate Account and the registration of such
separate account with the Securities and Exchange Commission. Accordingly, we are familiar with the
corporate records, certificates, and consents of officers of ANICO as we have deemed necessary or
appropriate for the purpose of this opinion.
Based upon the foregoing, and our consideration of such other matters of fact and questions of law
as we have deemed necessary and proper in the circumstances, we are of the opinion that:
1. ANICO is a duly organized and existing corporation under the laws of the State of Texas
and that its principal business is to be an insurer.
2. The Separate Account is a duly organized and existing separate account of ANICO under the
laws of the State of Texas and is registered as a unit investment trust under the Investment Company Act
of 1940.
3. The Variable Annuity Contracts registered by this Registration Statement under the
Securities Act of 1933 and the Investment Company Act of 1940 (File No. 333-33856) will, upon issuance
thereof, be validly authorized and issued.
We hereby consent to the use of our opinion of counsel in the Post-Effective Amendment No. 9 to
Form N-4 Registration Statement (File No. 333-33856) filed on behalf of the Separate Account. We further
consent to the statements made regarding us and to the use of our name under the caption "Legal Matters"
in the statement of additional information constituting a part of such Post-Effective Amendment No. 9 to
such Registration Statement.
Yours very truly,
XXXXX, XXXX & XXXXX, L.L.P.
Xxxxxxx X. Xxxxxxxx
