The defendant shall be innocent.

1. From around September 2015, the Defendant is running a “C”, which is a senior long-term care institution for senior citizens located in Yongsan-gu Seoul, Yongsan-gu, Seoul, and provided long-term care services to inmates while managing employees, such as affiliated caregivers and assistant nurses.

From July 2008, the National Health Insurance Corporation (hereinafter referred to as the "victims' Long-Term Care Insurance Corporation") provides beneficiaries who have difficulty in living a daily life due to elderly or sexual illness through the elderly long-term care insurance system with facilities (admission to long-term care facilities) and benefits for home care, etc., and provides them to operators of long-term care institutions. A long-term care institution provides long-term care benefits in accordance with the criteria, procedures, methods, etc. for providing long-term care benefits pursuant to Article 35 (2) of the Long-Term Care Insurance Act and Article 39 (3) of the same Act and Article 32 (Methods and Items of Calculating Standard for Providing Long-Term Care Benefits and Benefit Benefits) of the Enforcement Rule of the same Act shall apply for long-term care benefits in compliance with the announcement publicly notified by the Minister of Health and Welfare pursuant to Article 35 (2) of the same Act.

Accordingly, an operator of a long-term care institution shall pay expenses incurred in providing benefits to all beneficiaries in proportion to the actual vacancy of human resources. Therefore, if a vacancy occurs for a caregiver, etc. in breach of the guidelines for employee placement, the victim should claim the following expenses for benefits that accurately enters the number of standards for employee placement by accessing the victim’s website whenever the vacancy occurs.

The Defendant, despite being well aware of the foregoing provisions, demands the Victim to pay expenses for long-term care benefits (hereinafter referred to as “expenses for benefits”).