1. The insurance contract mentioned in paragraph 2 of the attached Table is due to the insurance accident described in paragraph 1 of the attached Table.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Plaintiff and Defendant A entered into an insurance contract for a business automobile (hereinafter “instant insurance contract”) with the same content as that of the attached Table No. 2 with respect to the B used aircraft (hereinafter “instant used aircraft”).

B. Defendant Gangnam General Construction Co., Ltd. (hereinafter “Defendant Co., Ltd”) was awarded a contract with Korea Co., Ltd. for the construction of an industrial boiler production plant in the Section C in Silung-si (hereinafter “instant construction”).

C. On November 13, 2013, when Defendant A was driven by, the Plaintiff, the Plaintiff, at the construction site of this case, set up a panel on the roof, and thereby, the structural part that was already executed by the two companies, the subcontractor of the instant construction, was destroyed.

(hereinafter “instant insurance accident”). D.

According to the insurance contract of this case, ① An insurance company compensates for losses sustained by the insured as a result of removal or damage of other's property due to an accident of an insured automobile occurred during the possession, use or management of the insured automobile, but ② an insurance company's obligation to pay insurance proceeds is exempted with respect to the damage incurred by the property owned, used or managed by the insured's employer when the insured is engaged in his/her business (hereinafter "instant exemption clause").

2. The parties' assertion

A. The Plaintiff’s assertion (i.e., the Defendant Company leased the key of the term of this case to Defendant A, and thus, is the employer of Defendant A.

D. The insured incident of this case occurred in relation to the property owned, used, or managed by the Defendant Company while Defendant A, the insured, is engaged in the business of the Defendant Company.