2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

2. The gist of the Plaintiff’s assertion asserts that, on the following grounds, the Plaintiff does not have the Plaintiff’s obligation to pay insurance money to the Defendant for an explosion accident in the instant insurance contract.

D, E, F, and G (hereinafter referred to as "D, etc."), unless otherwise specifically specified, means "D, etc.".

(B) Since the Defendant was not an employee at the time of entering into the instant insurance contract, the part of the instant insurance contract with D, etc. is null and void. (B) Even if the instant insurance contract was concluded effectively, since D, E, and F were to serve as an employee of H, not the Defendant, from April 1, 2017, and from June 7, 2017, G was deemed to have been terminated. (c) The part of the instant insurance contract with D, etc., of the instant insurance contract was deemed to have been terminated. Since the Defendant did not have a collective agreement on the conclusion of the instant insurance contract, the Defendant’s written consent is necessary for each insured to enter into the instant insurance contract. There was no fact that D, E, F, and G was signed with written consent, and thus, the part of the instant insurance contract with D, etc. was null and void. The Defendant notified the Plaintiff as an on-site manager (injury to water supply) at the time of entering into the instant insurance contract, and the Plaintiff is not obligated to pay insurance money to the Defendant as the insurance contract.

3. Determination as to the cause of action

A. The relevant legal entity’s organization serves as the insured all or part of its members and concludes a contract with its policyholder as the beneficiary.