2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

A. In accordance with the Act on the Establishment and Management of Seoul National University, the Plaintiff was established on December 28, 201 and comprehensively succeeds to the rights and obligations of the State that occurred in relation to the management of the previous Seoul National University, and is a national university foundation that manages the Seoul National University.

B. On November 15, 1980, the Minister of Construction and Transportation, under Article 369 of the notification of the Construction Division on November 15, 1980, determined and publicly announced as urban planning facilities (parks) the same size of 20,609,061 square meters, such as the new forest dong, Sacheon-dong, Seoul Special Metropolitan City, Gwanak-gu, as a natural park. On December 23, 1983, the Minister of Construction and Transportation determined and publicly announced the creation plan to create the Hosan Masan Natural Park by dividing it into the Hotensiona District, the Amar Cancer District, the Shindong-dong District, the Hocheon-dong-dong District, and the Amar B

C. After several times, the Mayor of Seoul Special Metropolitan City announced the development plan for the Cheongsan Urban Natural Park among the Cheongsan Urban Natural Park under Article 2017-6 of the Seoul Special Metropolitan City’s notification on January 5, 2017 and the development plan for the Cheongsan Urban Natural Park among the Cheongsan Urban Natural Park under Article 2017-6 of the Seoul Special Metropolitan City’s notification.

(hereinafter referred to as the “instant creation plan”) d. the final revised plan to create a city natural park in Masan (hereinafter referred to as the “instant creation plan”).

The Plaintiff completed the registration of ownership transfer on February 22, 2012 with respect to 41-4 woodland 59,198 square meters, such as Dobong-dong 256-1, 256-1, 296 square meters, Seocheon-gu, Seoul Special Metropolitan City. According to the instant creation plan, all of the land is transferred to the scarak-gu, Seosan Urban Natural Park Site.

E. In accordance with Article 139(2) of the National Land Planning and Utilization Act (hereinafter “National Land Planning Act”) and Article 68(1) [Attachment Table 4] 10(c) of the Seoul Special Metropolitan City Ordinance on Urban Planning, the Defendant is an administrative agency to which the head of Seoul Special Metropolitan City is delegated the authority to prepare, authorize, and publicly announce an implementation plan for urban planning facility projects, and to make the public inspection and public announcement for implementation plans.