1. The plaintiff (Counterclaim defendant) based on the insurance contract as shown in the attached Table 2 in relation to the insurance accident stated in the attached Table 1.

1. Facts without dispute;

A. On January 11, 2010, the Defendant concluded with the Plaintiff and the insured as C, and entered into an insurance contract with the beneficiary as specified in attached Table 2 (hereinafter “instant insurance contract”).

Some of the general terms and conditions and special terms and conditions applicable to the instant insurance contract are as follows.

Article 18 (Insurance Money for Social Disability) (2) of the General Terms and Conditions: Where the insured was injured by an accident as prescribed in Article 15 (Compensation for Damages) and the injury was cured, and the company has, as a direct result, lost part of the body within two years from the date of the accident or has permanently lost its function (hereinafter referred to as the "Ex Post Facto Disability") and the rate of payment specified in the Disability Classification Table remains, the company shall pay to the beneficiary an amount calculated by multiplying the insurance amount covered by the insurance policy for the bodily disability after the death or disability as stated in the Insurance Policy (Certificate of Insurance) by the rate of payment prescribed in the Disability Classification Table.

Article 3 of the Special Clause on Security of Disability Pension with 50% or more of the injury (age pension with 50% or more of the injury) ① A company shall pay the amount of insurance coverage for the post-age disability pension with 50% or more of the injury as stated in the insurance policy (insurance Policy) to beneficiaries of disability pension for 10% or more of the injury every ten years from the date of the accident, if the insured was suffering from the injury as a result of the accident as prescribed in Article 1 (Compensation for Loss) and the injury was cured, and the bodily part is lost within 2 years from the date of the accident, or the function thereof is permanently lost, or there was a remaining disability of 50% or more as prescribed in the disability classification table as a result of the direct result of the accident.

Provided, That the payment of a disability pension with an injury of at least 50% shall be determined 120 times.

(5) If two or more subsequent disabilities are caused by the same accident, it shall be paid by adding up the rate of payment of the subsequent disability.

B. C is front of the D Apartment-gu Gwangju Mine on January 18, 2011.