1. Insurance proceeds based on the insurance contract described in attached Form 2 against the Defendant (Counterclaim Defendant) of the Plaintiff (Counterclaim Defendant).

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On April 13, 2004, B entered into an insurance contract (hereinafter “instant insurance contract”) including a special agreement for non-distribution disaster death (hereinafter “instant special agreement”) in attached Form 2 with the Plaintiff as the insured of C, and entered into an insurance contract (hereinafter “instant insurance contract”).

B. Of the terms and conditions of the instant insurance contract, the contents pertaining to the instant case are as follows.

(1) Article 17 (Types and Grounds for Payment of Insurance Money) of the Agreement of the State of this case shall pay to the insured the insurance money agreed upon to the beneficiary (referring to the attached Table I "Standards for Payment of Insurance Money") when any of the following events occurs to the insured:

1. When the insured dies during the insurance period (the insured events for which no insurance money is paid) ① The company may terminate this contract simultaneously with the failure to pay the insurance money when any of the following events occurs:

1. Where the insured intentionally damages himself/herself, but this shall not apply to cases where the insured has impaired himself/herself from a mental disorder and where he/she has committed suicide after two years from the date of commencement of liability for the contract, or has caused harm to himself/herself, thereby becoming a disability of Grade I in the disability classification table;

(Annex 2) The sub-sea accident refers to an accident that occurs as a contingent external factor (Provided, That where a person who has a disease or a physical constitution factor suffers from a minor external factor or has aggravated symptoms, the minor external factor shall not be considered as an contingent external accident) and is subject to the following classification:

(2) Article 9 of the Terms and Conditions of the instant Special Agreement (Types and Grounds for Payment of Insurance Money) provides that the company shall pay the insurance money to the company.