1. Regarding the accidents listed in the attached Form 1, the defendant limited partnership company of the plaintiff (Counterclaim defendant) based on the insurance contract listed in the attached Form 2.

1. Basic facts

A. On May 17, 2012, the Plaintiff entered into a collective insurance contract in attached Form 2 with Defendant Limited Partnership Company A (hereinafter “Defendant Company”) with the insured, and with the Defendant Company as beneficiary (hereinafter “instant insurance contract”). The terms and conditions of the instant insurance contract are as follows.

1) Article 17 of the General Terms and Conditions of the Contracts for the Protection of Disasters (hereinafter referred to as "the Insurance Contract") provides that the insured shall pay the insurance proceeds agreed upon to the beneficiary when any of the following events occurs during the insurance period. 1. An insured event for which the insured does not pay the insurance proceeds under Article 19 of the Insurance Proceeds for the Protection of Disasters (hereinafter referred to as "the Insurance Risk") shall not be bound to pay the insurance proceeds when any of the following events occurs: 1. Where the insured intentionally damages himself/herself: Provided, That this shall not apply to the following cases: 1. Where the insured intentionally damages himself/herself under the condition that it is impossible for him/her to make a free decision due to a mental disorder, etc., the Insurance Proceeds for the Death of the Insured under the condition that he/she cannot make a free decision due to mental disorder, etc. (attached Table 1).

1. Any of the following disasters subject to coverage shall be paid insurance proceeds in accordance with the terms and conditions of this insurance:

(2) Infectious diseases as defined in subparagraph 2 of Article 2 of the Infectious Disease Control and Prevention Act, as defined in subparagraph 2 of the same Article.

2. Any of the following accidents for which insurance proceeds are not paid: