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1. With respect to the accidents listed in the attached Form 1, the plaintiff (Counterclaim defendant) based on the insurance contract listed in the attached Form 2.
Reasons
A principal lawsuit and a counterclaim shall be deemed simultaneously.
Basic Facts
On December 30, 2010, B, the father of the defendant, entered into the instant insurance contract with the insured as the defendant, the beneficiary B (in the event of death: B, out of death: B) and with disability insurance with less than 80% of the death of an injury (in the event of a general injury with less than 80% disability, payment shall be made by multiplying the rate of disability payment), 20,000,000, and insurance money for injury after death of an injury (in the event of death or after death of an injury with a general injury, payment shall be made by multiplying the rate of disability payment) with the subscription amount of 80,000,000 won.
Among the general terms and conditions and special terms and conditions of the instant insurance contract, the contents relating to the instant case are as follows.
【Insurance Terms and Conditions】 Article 15 (Types and Grounds for Payment of Insurance Money) The Company shall pay the insurance money agreed upon to the beneficiary (beneficiary) when any of the following events occurs to the insured (beneficiary):
During the insurance period, the insured (subject of insurance) suffers an injury after 15 years of age (excluding physical protection equipment, such as trees, artificial arms, legs, bills, and dental arms, due to an accident that happens during the insurance period, but also includes cases where his/her body is transplanted, such as artificial organs or parts, and thus his/her function is replaced.
hereinafter the same shall apply)
) If the insured dies as a direct result of the injury (hereinafter referred to as “injury”) (other than death due to illness), the full amount of the insurance coverage shall be paid to the beneficiary (the beneficiary of the insurance, and the heir of the insured (the beneficiary of the insurance) if not designated as the beneficiary) with the General Injury Death Insurance Money.
If there is a disability equivalent to a disability rate less than 80% specified in the disability classification table (see the disability classification table in attached Table 1; hereinafter the same shall apply) during the insurance period, the disability payment rate prescribed in the disability classification table shall be the amount of insurance coverage.