1. With respect to an accident listed in the separate sheet No. 1, the plaintiff (Counterclaim defendant) based on the insurance contract listed in the annexed sheet No. 2.

(b) the facts of the basis;

A. The network D (hereinafter “the deceased”) married with Defendant A and placed Defendant B and C as his child.

B. On February 4, 2013, Defendant C concluded an insurance contract between the Plaintiff and the insured, and the beneficiary of the insurance as the heir, as indicated in the separate sheet (hereinafter “instant insurance contract”).

The main contents of the instant insurance contract are as follows.

[Ordinary Terms and Conditions]

1. Injury after disability (3 to 100%, 100 years of age): 100 million won (special terms and conditions);

3. Injury or death (100 years of age): 100 million won;

4. Injury by at least 80% (100 years of age): 100 million won;

8. New and comprehensive hospitalization medical expenses (three-year renewal, 100 years of age): 50 million won * Beneficiary of death insurance proceeds * Legal heir of the insured * Beneficiary of surviving insurance proceeds : the insured.

C. Around April 26, 2015, the Deceased fell from his house stairs located in Kimcheon-si, and was treated at the E Hospital, but died as “cerebral damage, cerebral side, cerebral side, and leuk-bladymosis” on the following day.

(hereinafter “instant accident”). D.

The Defendants demanded the Plaintiff to pay the injury death insurance money under the instant insurance contract, but the Plaintiff refused to pay the insurance money on the ground of breach of duty of disclosure, etc.

[Ground of recognition] Facts without dispute, entry of Gap1 to 5 evidence, purport of the whole pleadings

2. The Plaintiff asserts that the instant insurance contract was null and void as there is no written consent of the deceased, the insured at the time of signing the contract, and that there is no liability to pay the insurance money based on the instant insurance contract in relation to the instant accident, inasmuch as the Defendant C, upon entering into the insurance contract, did a fraudulent act that did not inform the Plaintiff of the deceased’s disease, such as liver and urology disease, etc., such fraudulent act.

First of all, the plaintiff's primary claim is null and void on the ground of non-existence of written consent.