1. As to the insured events listed in the attached Form 1, the plaintiff is against the defendant according to the insurance contract listed in the attached Form 2.

1. Basic facts

A. On April 18, 2014, the Plaintiff and the Defendant concluded an insurance contract indicated in attached Form 2 (hereinafter “instant insurance contract”) that guarantees the payment of insurance proceeds when the insured died due to a traffic accident or suffered from a disability due to a traffic accident (hereinafter “instant insurance contract”).

B. On March 18, 2016, the Defendant filed a claim with the Plaintiff for the payment of the remainder disability insurance proceeds by asserting that the Plaintiff had suffered from the instant insured incident listed in attached Form 1 (hereinafter “instant accident”) and that the considerable loss of the ex post facto disability guaranteed by the terms and conditions of the instant insurance contract remains.

C. The terms and conditions of the instant insurance contract are as follows.

Payment of insurance money under Sub-Section 2

3. A cause for the payment of insurance proceeds (1) A company shall pay the insured insurance proceeds agreed upon to the beneficiary in any of the following cases:

1. Any traffic injury during the insurance period (excluding physical assistive equipment, such as clothes, artificial arms, bills, and clothing, which has occurred during the insurance period, but including cases where a body is transplanted, such as artificial organs or partial arms, and its function is replaced by another traffic accident which occurs during the insurance period;

) If the person dies as a direct result of the injury sustained (hereinafter referred to as “transport injury”) (other than death due to disease): the amount of insurance coverage for traffic injury, death (the amount of insurance coverage for traffic injury, death, and aftermath disability):

2. If the rate of disability payment specified in the disability classification table (refer to attached Table 1) as the direct result of the traffic injury during the insurance period amounts amounts to not less than 80%: Insurance money for the traffic injury, injury, high level, and aftermath disability (the amount of insurance coverage for the traffic injury, death and after death); and

3. If the rate of disability payment determined in the disability classification table as a direct result of the traffic injury during the insurance period period, falls short of 80%: Such disability shall be determined in the traffic injury, general disability insurance table; and