1. With respect to an accident described in the separate sheet (1), the Plaintiff (Counterclaim Defendant) based on the insurance contract indicated in the separate sheet (2).

Basic Facts

A principal lawsuit and a counterclaim shall be deemed simultaneously.

On June 21, 2010, Defendant A, who represented the deceased C (hereinafter “the deceased”), entered into a family love insurance contract (hereinafter “instant insurance contract”) between the Plaintiff and the Plaintiff for the happiness of non-distribution as described in the following table, and paid the first insurance premium to the Plaintiff around that time.

[Contents of Insurance Contract] From June 21, 2010 to June 21, 2068, the insurance premium of KRW 100 million for general injury death benefit of KRW 100 million for general injury death benefit of KRW 238,220 per year (payment of annual accident for 10 years) for 20 years (i.e., basic insurance premium of KRW 13,900 for basic insurance premium of KRW 151,471 for accumulated insurance premium of KRW 72,849)

B. At the time of the conclusion of the instant insurance contract, the Deceased submitted “responsibilities to inform the insurance solicitor affiliated with the Plaintiff,” and according to this, the Deceased indicated on the column that he will drive his own car, but did not separately indicate the column that he will drive the Otobane.

On November 5, 2014, the Deceased was killed in the same place due to an accident (hereinafter referred to as “instant accident”) caused by shocking the head of the steel rail while driving the Obaba (D) on his own on November 5, 2014, driving through the sub-committee of the Busan Gangseo-gu Incheon Metropolitan City Southern Sea and passing through the sub-section of the sub-committee of the sub-section 2.

C. At the time of the death of the deceased, there is Defendant A and the mother of the wife, who is the bereaved family member.

In December 15, 2014, Defendant A claimed the Plaintiff to pay the general injury and death benefit amount according to the instant accident. However, the Plaintiff purchased two-wheeled automobile on August 13, 2013 after the conclusion of the instant insurance contract to Defendant A, the policyholder, and repeatedly boarded, owned, and managed it until the date of the instant accident.