1. A driver listed in attached Form 2 in relation to an incident listed in attached Form 1.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Plaintiff entered into an insurance contract with the deceased D (hereinafter “instant insurance contract”).

B. On December 16, 2016, the network D was a worker belonging to the guard service company, and was dispatched to the F Co., Ltd. located in Daegu-gu E on December 16, 2016

From December 16, 2016 to 15:30 on December 16, 2016, the car of the 4th aircraft for cargo in F Co., Ltd. stopped on the second floor due to the breakdown of the 4th aircraft in F Co., Ltd., and some parts of the 1st floor platform were opened without leaving.

around that time, as shown in attached Table 1, the above D fell from the above first floor platform to the first basement, and the accident that died around December 16, 2016 (hereinafter “instant accident”) occurred.

C. Defendant A is the wife of the above D, and Defendant B and C are children and their legal successors D.

The terms and conditions concerning traffic injury (hereinafter “instant terms and conditions”) among the instant insurance contracts are as follows.

Article 3 (Grounds for Payment of Insurance Money) (1) The Company shall pay the insured insurance money 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 artificial organs or partial arms, which are transplanted and substituted for its function as a result of a traffic accident;

(i)an injury suffered (hereinafter referred to as “traffic injury”)

(ii)in the case of death as a direct result of the traffic injury (excluding death due to a disease);

(2) The traffic injury under paragraph (1) means the following injury:

The collision, contact, or the collision, contact, fire, of these means of transport.