A. On October 26, 2009, the Plaintiff sold KRW 600,000 square meters of G forest in Ulsan-gun, Ulsan-gun, Ulsan-do (hereinafter “1 real estate”) to KRW 1.855,500,000,000,000,000, and at the time of the contract, the remainder of KRW 100,000,000,000 out of KRW 200,000,000 was paid as of November 10, 2009, and the remainder of KRW 1.655,00,000,000 was paid as repayment of ownership transfer registration (hereinafter “the first sales contract”).

B. Around October 28, 2009, the Plaintiff sold 8694 square meters of forest land in Ulsan-gun, Ulsan-gun, U.S. (hereinafter “second real estate”) to KRW 5.245 billion, but at the time of the contract, KRW 300 million out of the down payment of KRW 500 million was paid on November 10, 2009, and the remainder amount of KRW 4.745 million was paid on December 28, 2009 (hereinafter “second sales contract”). The Plaintiff agreed to be paid as repayment for ownership transfer registration on December 28, 2009 (hereinafter “second sales contract”).

C. Both the 1 and 2 sales contracts stipulate a special agreement that if the contract is terminated due to a breach of contract, the down payment shall be deemed as the basis for net damages. At the time of the 2 sales contract, the Plaintiff, Defendant B, C, and D agreed to the effect that the 1 and 2 real estate shall be calculated as KRW 160,000 per square year and treated KRW 7.1 billion per square year.

Defendant B, C, and D paid to the Plaintiff the down payment of KRW 700 million under the 1 and 2 sales contract, and paid KRW 4.5 billion out of the remainder 6.4 billion on December 29, 2009, and completed the registration of transfer of ownership over the 1 and 2 real estate in the future of the Defendants as to each of the 1/3 shares on the same day. On the same day, Defendant B, C, and D completed the registration of establishment of ownership over the 1 and 2 real estate as joint security by using the 1 and 2 real estate as the debtor B, the maximum debt amount of KRW 3.51 billion on the same day, and completed the registration of establishment of ownership over the 1 and 2 real estate of the Gyeyang Agricultural

E. On March 21, 2013, Defendant E purchased Nos. 1 and 2 real estate in the discretionary auction procedure applied for by the speech-gu Agricultural Cooperative based on the right to collateral security as set forth in the said paragraph and completed the registration of ownership transfer on the same day.

F. The Plaintiff is KRW 100 million before October 16, 2012.