1. With respect to an accident described in attached Form 1, the Plaintiff (Counterclaim Defendant) based on the insurance contract as stated in attached Form 2.

1. Basic facts

A. On February 20, 2008, B entered into an insurance contract between the Plaintiff and the Defendant as the insured and beneficiary (hereinafter “instant insurance contract”) in attached Form 2 (hereinafter “instant insurance contract”).

B. Of the terms and conditions of the instant insurance contract (hereinafter “instant insurance terms and conditions”), the key contents pertaining to the instant insurance contract are as follows.

Article 16 (2) of the General Terms and Conditions: In case the insured was injured by an accident as provided for in Article 13 (Compensation for Damages) and the injury was cured, and the company has lost part of the body within two years from the date of the accident as a direct result of the accident, or has lost its function permanently (hereinafter referred to as "ex post facto disability") and the latter disability (hereinafter referred to as "general ex post facto disability") whose rate of payment as provided for in the Disability Classification Table remains less than 80%, the company shall pay as general ex post facto disability insurance proceeds an amount calculated by multiplying the insurance coverage amount stated in the insurance policy (insurance Policy) by the rate of payment as provided for in the Disability Classification Table.

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

However, if the criteria for determining each physical parts of the disability classification table are separately prescribed, it shall be at the risk of complying with such criteria.

Article 25 (Obligation to Notify before Contract) The contractor, the insured, or their agents are aware of the fact that they are asked questions at the time of subscription (in the case of a diagnosis contract, including the time of health examination) (hereinafter referred to as "duty to notify before contract," and the same as "Duty to notify" under the Commercial Act).

Article 26 (Duty to Notify after Contract) ① The contractor or the insured shall either alter his occupation or duty (including the case where the self-employed driver changes his occupation or duty as a driver for business) or directly use the two-wheeled automobile or motor bicycle.