1. The plaintiff (Counterclaim defendant) based on the insurance contract as shown in the attached Form 2 with respect to the insured events listed in the attached Table 1.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Facts of recognition;

A. On September 11, 2015, the Plaintiff entered into a mid-term equipment safety insurance contract (hereinafter “instant insurance contract”) with the Defendant with a view to guaranteeing liability for damages or the insured to be borne by the insured for damages incurred in the subject matter of insurance, as described in the attached Table 2, with respect to the subject matter of insurance between the Plaintiff and the company operating a non-life insurance business, etc. and the Defendant.

B. The general terms and conditions of heavy equipment safety insurance (hereinafter “instant terms and conditions”) serving as the main contents of the instant insurance contract include, in relation to the instant case, the following:

Article 1 (Purpose) of the General Terms and Conditions for Equipment Safety Insurance (Purpose) is to guarantee the risk of damage or the risk of injury of the insured caused by the insured's burden of statutory liability for damages caused by the insured's loss to the subject of the insurance between the policyholder and the insurance company.

§ 34 (Compensation for Loss) ① A company shall compensate for losses sustained by an accident that happens during the cover period.

(2) Where a loss occurs due to a risk guaranteed under paragraph (1), the company shall additionally pay the following expenses paid by the policyholder or the insured:

1. Expenses for prevention of loss: Expenses disbursed or beneficial to prevent or reduce loss;

4.Other co-operation costs: necessary or beneficial costs incurred to comply with the Company’s requirements (non-compensationable damages) ① The Company shall not compensate for the following losses:

11. Damage caused by the violation of Acts and subordinate statutes, or other rules;

C. At around 17:30 on April 25, 2016, the Defendant’s employees B, who suffered an accident, shall drive the instant resistance engine at the site of a road expansion and packing construction site located in the area in the area where the former west-gun C is located and move to the working place.