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1. The plaintiff (Counterclaim defendant) based on the comprehensive motor vehicle insurance contract indicated in the attached Form in relation to the motor vehicle accident indicated in the attached Form.
Reasons
A principal lawsuit and a counterclaim shall be deemed simultaneously.
1. Occurrence of liability for damages;
A. Facts of recognition 1) The Plaintiff is the Plaintiff’s car (hereinafter “Plaintiff’s car”) between C and C.
A) On September 3, 2011, at around 22:00 on September 3, 201, the insurer that entered into a comprehensive automobile insurance contract with the insurance period, including the following date and time of the accident. (2) around September 22:0, 201, E, the spouse of C, was driving the Plaintiff’s vehicle in the vicinity of the south-west branch office in the Chungcheongnam-do Seoul Special Metropolitan City, Chungcheongnam-do, Chungcheongnam-do, where the Defendant’s driver stopped for the atmosphere signal, resulting in an accident (hereinafter “the instant accident”).
4) After the instant accident, the Plaintiff was diagnosed by G Council members from September 5, 201 to September 10, 201, from September 30, 2011, to H Hospital from September 11, 201, from H Hospital to November 11, 201, respectively hospitalized at the I Hospital from November 13, 201 to November 24, 201, and is being treated in the course of rehabilitation and medicine, etc. (including being hospitalized at the I Hospital, respectively, during the period from November 13, 2011 to November 24, 201).
B. According to the facts of recognition as above, the accident of this case was entirely caused by the negligence of E, and according to the Guarantee of Automobile Accident Compensation Act, C, the owner of the Plaintiff vehicle, is liable for the Defendant’s damages, and the Plaintiff, the insurer, bears the same responsibility as C.
2. Scope of liability for damages
(a) In addition to the following separate statements, each corresponding item in the attached Form of damages calculation sheet shall be the same as the corresponding item, and the period for the convenience of calculation shall be calculated on a monthly basis in principle, but less than the last month and less than KRW 1 shall be discarded.
The calculation of the current value at the time of the accident shall be based on the reduction rate of 5/12 percent per month to deduct the interim interest.
And the parties' arguments.