1. The Plaintiff (Counterclaim Defendant)’s liability for damages against the Defendant (Counterclaim Plaintiff) with respect to the incident described in the attached Form.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Facts of recognition;

A. The Plaintiff is a juristic person that establishes and operates the Seocho-gu Medical Care Center for the Aged (hereinafter “instant Medical Care Center”) as a sanatorium for the Aged at 58, Seosan 2-ro, Seosan-si.

B. A (F) was diagnosed with dementia and entered into a contract for long-term care benefits with the Plaintiff from July 30, 2013, and was admitted to the instant hospital and received medical care services. The Defendants are children of A.

C. At around 11:00 on March 6, 2015, G care workers of the instant medical center reported that A contests with other inmates of the instant medical center’s corridor from the instant medical center’s corridor, and sought to isolate A as 309 the instant medical center by neglecting A.

At that time, A put G in the above 309 and closed the door outside.

Accordingly, G was in the process of opening a door to the above 309, and as a result, A was in the process of taking a door to the right of the reading center, and as a result, A was in the occurrence of an accident in which A entered the framework between the upper right of the bar. D

A undergoes medical treatment at the emergency department of the Seosan Medical Center on the same day, and after March 26, 2015 to May 16, 2015, A received necessary medical treatment at a designated university hospital, such as hospitalized and receiving necessary surgery at the designated university hospital from March 26, 2015 to May 16, 2015.

E. Meanwhile, A died on August 15, 2016, and the Defendants inherited the network A (hereinafter “the deceased”).

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, Eul evidence Nos. 1 through 12 (including each number), the purport of the whole pleadings

2. Occurrence of liability for damages;

A. According to the above facts of recognition of responsibility, the Plaintiff and its employees, who are operators of pay long-term care facilities, have a duty to manage and protect the instant patients so that they may not cause safety accidents to the inmates of the instant medical care center. In particular, the Deceased is an elderly dementia patient, and the Deceased is due to dementia.