Respondent： ______________
Address：__________________
The following answer is hereby given to the claim of ______ for compensation by the ______ People's Hospital for personal injuries：
1. The respondent does not have a direct contractual relationship with ______. The respondent entered into an oral contract with ______ No ______ Construction and Installation Company on ______（M,D,Y）, whereby ______ No ______ Construction and Installation Company shall be responsible for removing the high-voltage meter cabinet. ______ was engaged in removing the high-voltage meter cabinet as entrusted by ______ No ______ Construction and Installation Company and therefore has no direct contractual relationship with the respondent.
2. The liabilities for compensating ______ for the damage shall be born by ______ No ______ Construction and Installation Company for the following reasons. Firstly, pursuant to PRC laws and relevant judicial interpretations, ______ No ______ Construction and Installation Company shall be liable for any injuries suffered by its employees to the extent of the contract performance. The injuries of ______ was not caused by anything other than the object of the contract. Thirdly, ______, who was entrusted by ______ No ______ Construction and Installation Company, seriously violated the operational procedure in removing the high-voltage meter cabinet and failed to pay due attention thereto.
3. The respondent shall not be liable for compensating the injuries of______. In accordance with the General Principles of the Civil Law, any person engaged in highly dangerous operation shall be liable for compensation in the event of any damages. In this case, however, the respondent entered into a contract with ______No ______ Construction and Installation Company, whereby the source of high danger shifted to ______ No ______ Construction and Installation Company legitimately. ______ No ______ Construction and Installation Company became the subject of the dangerous operation, and therefore any damages caused in the contract performance by ______ No ______ Construction and Installation Company has no connection with the respondent.
By reason of the foregoing, _______People's Court is not legible for becoming the defendant. We hereby request the court to reject the plaintiff's action according to law.
To：
_____City Intermediate People's Court
Respondent：____ People's Court
Date：_________________________
