1. With respect to the accidents described in paragraph 1 of the Schedule, time-limit for the insurance contract described in paragraph 2 of the Schedule.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

Basic Facts

The following facts may be acknowledged if there is no dispute between the parties, or if Gap evidence Nos. 1 through 11 (including each number in case of additional numbers), and Eul evidence No. 2 show the purport of the whole pleadings:

The plaintiff and the defendant entering into an insurance contract operate a postnatal care center in Asan City B (hereinafter referred to as the "postnatal care center of this case").

On December 28, 2012, the Defendant entered into a fire comprehensive insurance contract on the postnatal care center of this case (the same as the insurance contract listed in attached Table 2; hereinafter referred to as the “instant insurance contract”) with the insurer and the Defendant as the insured. At the time of the said contract, the Defendant set the maximum amount of compensation KRW 100,000,000, and entered into a special agreement on the liability of the owner of the facilities to compensate for the damages.

Among the instant insurance contracts, the special terms and conditions for the liability of the owner of the facility (management) (hereinafter “the instant special terms and conditions”) stipulate as follows:

C. Foods

1. (Types and Grounds for Payment of Insurance Money) Any insurance company shall be bound to indemnify for any loss sustained by the insured (person subject to insurance) specified in the insurance policy during the insurance period of this Special Terms and Conditions by causing physical harm to another person or by causing damage to another person's body or by causing damage to another person's property due to any unexpected accident that occurs in the course of performing the business affairs in accordance with the use of such facilities;

2. (Detailed Provisions Concerning Payment of Insurance Proceeds) The scope of damages covered by an insurance company per one accident shall be as follows:

(1) Legal damages that are liable for the insured to pay to the victim shall be statutory damages.

3. (Grounds for Not Payment of Insurance Money) An insurance company shall not pay any loss for any of the following reasons:

(5) The insured and others shall have an agreement on compensation for damage.