A. On July 22, 2008, A Co., Ltd. (hereinafter “Plaintiffs” was merged into B Co., Ltd. as of July 2, 2020; hereinafter referred to as “the merger”) jointly and severally guaranteed the obligation to C under the Housing Sale Guarantee Agreement (hereinafter “instant Housing Sale Guarantee Agreement”) entered into between the Defendant and C Co., Ltd. (hereinafter “C”) on July 22, 2008.

(hereinafter referred to as “instant joint and several sureties contract”). (b)

C On August 24, 2010, the Defendant expressed his/her intent to rescind the instant house sale guarantee contract, and claimed the return of KRW 2,930,842,00 of the guarantee fee.

C. On February 8, 2011, the Defendant returned KRW 472,152,00 after deducting the guarantee fee of KRW 2,458,690 from the guarantee fee of KRW 2,930,842,00 paid by C to C from the approval date of the tenant invitation to the cancellation date of approval.

C A lawsuit was filed against the Defendant on July 12, 2013, seeking the return of KRW 2,458,690,000, which was deducted by Seoul Southern District Court 2013Kahap1067, and the said lawsuit was dismissed following the appellate court, the final appeal, and the appellate court, and the appellate court. On September 26, 2019, the Supreme Court dismissed the appeal against the judgment of the appellate court for the reversal and the appellate court, and the judgment against C was final and conclusive.

E. The Defendant filed an application for the determination of the amount of litigation costs with Seoul Southern District Court Decision 2019Kadan11396, and received a decision to confirm that C is KRW 43,638,704, the amount of litigation costs to be repaid to the Defendant.

The above decision on the amount of litigation costs became final and conclusive thereafter.

F. Around January 16, 2020, the Defendant filed a claim with C to reimburse the costs of lawsuit to be borne by C to the Plaintiff, and the Plaintiff rejected the claim. Around April 6, 2020, the Plaintiff notified the Plaintiff that his business transaction with C would be restricted if the Plaintiff did not reimburse the costs of lawsuit. Around April 20, 2020, the Defendant notified the Plaintiff that the issuance of a letter of guarantee will be interrupted if the Plaintiff did not reimburse the costs of lawsuit.

G. On May 21, 2020, in order to avoid the Defendant’s restriction on transaction and the suspension of issuance of a letter of guarantee.