1. The plaintiff (Counterclaim defendant) according to the insurance contract stated in the attached list (2) concerning the accident listed in the attached list (1).

1. Grounds for claim;

A. The purport of the Plaintiff’s assertion (the cause of the principal claim) asserts that “A person suffers permanent harm on the left shoulder side of the accident listed in the [Attachment List (1)” (hereinafter “the instant accident”) and claim for the payment of the insurance proceeds of the subsequent disability in accordance with the insurance contract indicated in the annexed List (2).

However, there is no subsequent disability of the defendant's assertion or there is no causal relationship with the accident of this case, and the plaintiff does not bear the obligation to pay the subsequent disability insurance money to the defendant.

B. The Defendant’s summary of the Defendant’s assertion (the cause of the counterclaim) also suffered from a sloping disorder (10% disability rate) due to the instant accident in accordance with the “routing routing routing routing routing routing rout (10%)” due to the instant accident, and also incurred a permanent residual disability (10% disability rate; hereinafter “underrout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout rout

2. Determination:

A. Whether proximate causal relation exists (based on the existence of the latter disability claimed by the Defendant), the primary core issue of the instant case is whether there exists a proximate causal relation between “the aftermathal disability in the field of the instant accident,” and “the aftermathal disability in the field of the instant accident,” respectively.

However, comprehensively taking account of the following circumstances revealed by the evidence Nos. 4-6 and Nos. 2, 4, 6, 8, 10-14, 16-19 (including each number), and the entire purport of the pleadings, the following circumstances are assumed to mean that “the existence of a post facto disability claimed by the Defendant exists” and the other evidence submitted by the Defendant is different.