A. A. Around June 2016, the Defendant: (a) contracted the construction of a complex construction project on the main land of Ulsan-gu and 7 parcels of land (hereinafter “instant construction project”) from the Plaintiff to KRW 8,496,319,038 (including additional taxes; hereinafter the same shall apply); and (b) completed the construction project around November 2017.

B. On February 9, 2018, E, on behalf of the Plaintiff and the Defendant, drafted a debt repayment contract document with respect to KRW 2,000,000,000 of the construction price of the instant case as “the creditors, the Defendant, the Plaintiff, and the due date of reimbursement, February 14, 2018” (hereinafter “Fair Deed”).

(c)

On February 24, 2020, the Defendant notified the Plaintiff of the transfer of the claim to F Co., Ltd. (hereinafter “F”) that “The Plaintiff and the Defendant transferred the instant construction cost and the interest accrued therefrom (as of January 5, 2020, principal KRW 835,427,637, interest KRW 65,053,791) to F Co., Ltd. (hereinafter “F”).

On July 6, 2020, F notified the Plaintiff of the assignment of the claim to the effect that “F intended to reorganize the above claim to the Defendant.”

(d)

On May 31, 2018, the Defendant notified G of the transfer of the claim that KRW 38,326,310, out of the claim for construction payment of the instant case was transferred to G.

G transferred the above claim to the Defendant on September 3, 2020, and notified the Plaintiff of the transfer of the claim on September 6, 2020.

On August 26, 2019, the Defendant transferred KRW 23,240,707, out of the instant claim for construction cost, to H, and notified the Plaintiff of the transfer of the claim on September 24, 2019.

H transferred the above claim to the Defendant on September 3, 2020, and notified the Plaintiff of the transfer of the claim on September 8, 2020.

E. I (J) transferred to the Plaintiff on August 24, 2020 the claim amounting to KRW 25,883,000, D drainage construction cost of KRW 4,400,00, and the construction cost of D on-site civil engineering work cost of KRW 286,00,000, and the claim amounting to KRW 5,400,000, and notified the Defendant of the transfer of the claim on the same day. L transferred the claim to the Defendant on August 19, 2020.