A. On December 18, 2009, the Dong-dong Development Co., Ltd. (hereinafter “Dong-dong Development”) entered into a construction contract (hereinafter “the second construction contract”) with the Ulsan Metropolitan City Dong-gu, Ulsan Metropolitan City (hereinafter “Ulsan-dong”), setting the construction cost of KRW 1,270,979,860 with respect to the “Ulsan-dong Park Construction Project,” and entered into a construction contract (hereinafter “the second construction contract”). On February 10, 2010, between Ulsan-gu and Ulsan-gu, the construction cost was KRW 1,150,439,140 with respect to the “Slsan-dong Park Construction Project,” and between Ulsan-gu and Ulsan-gu (hereinafter “the second construction contract”).

B. Advance payment 1) Defendant Construction Mutual Aid Association (hereinafter “Defendant Mutual Aid Association”) related to the first construction contract

B) On January 4, 2010, the period of the first construction contract was fixed as KRW 402,051,000, and the guarantee period from January 4, 2010 to December 22, 2010, with respect to the advance payment of the first construction contract between Ulsan-gu and Ulsan-gu (hereinafter referred to as “first guarantee”) and the guarantee agreement on the obligation to return advance payments to the Ulsan-gu Development during the period from January 4, 2010 to December 22, 2010.

Defendant Seoul Guarantee Insurance Co., Ltd. (hereinafter “Defendant Seoul Guarantee Insurance”)

B) On January 4, 2010, the period of the first construction contract is 269,849,320 won and the guarantee period from January 4, 2010 to February 21, 2011 with respect to the advance payment of the first construction contract between Ulsan-gu and Ulsan-gu (hereinafter referred to as “second guarantee”) and the guarantee agreement on the obligation to return advance payments to the Ulsan-gu Development (hereinafter referred to as “second guarantee”).

(2) Ulsandong-gu paid advance payment amounting to KRW 630,000,000 ( KRW 380,000,000 KRW 250,000) around January 5, 2010, in accordance with the payment guarantee under paragraphs 1 and 2.

3) With respect to the advance payment of the first construction contract between Ulsan-gu and Ulsan-gu on June 29, 2010, the Plaintiff paid a guarantee agreement on the obligation to return advance payments to Ulsan-gu and Ulsan-gu (hereinafter “payment guarantee”) with the period from June 29, 2010 to December 23, 2010, with regard to the guaranteed amount of KRW 262,670,790, and the guarantee period from June 29, 2010 to December 23, 2010.

AB concluded the agreement.

Defendant.