A. On August 14, 2002, the Defendant obtained approval of the business plan under Article 33 of the former Housing Construction Promotion Act (amended by Act No. 6732 of Aug. 26, 2002) and Article 32 of the Enforcement Decree of the same Act (amended by Presidential Decree No. 17816 of Dec. 26, 2002), and made it possible to construct two apartment houses with 210 households (hereinafter referred to as “D apartment”) which are public construction-based rental houses on the land area of 7,373 square meters outside Gapo-si and Gapo-si, with funding from the National Housing Fund under Article 33 of the former Housing Construction Promotion Act and Article 32 of the Enforcement Decree of the same Act.

B. On September 10, 2008, the Defendant entered into a lease contract with the winner upon receiving an application for occupancy according to the above public announcement of invitation, and on September 10, 2008, the Defendant entered into a lease contract with the Plaintiff and D Apartment 201 Dong 602 (hereinafter “instant rental housing”).

After that, the lease deposit for the instant rental housing was increased, and at present, the lease deposit for the instant rental housing was KRW 45,520,000.

C. On September 14, 2004, the Defendant completed the registration of establishment of a new apartment on the whole of the above apartment on September 14, 2004, and completed the registration of establishment of a new mortgage on the same day to the National Bank of Korea (hereinafter “National Bank”) which provided the whole apartment as a joint collateral against the National Housing Fund, and completed the registration of establishment of a new mortgage on the whole apartment as KRW 6.552 billion with the maximum debt amount.

The above joint collateral is the right to collateral security (hereinafter referred to as the right to collateral security (the actual secured debt amount is KRW 24 million) with respect to each unit of D apartment as of May 28, 2008, with the maximum debt amount of 31.2 million with respect to each unit of D apartment.

The registration of change has been completed.

Since then, the Defendant partly repaid the principal of the instant right to collateral security and remaining 20,814,430 won as the amount of the secured obligation.

On October 19, 2010, the council of lessees' representatives of D apartments applied for approval for conversion of D apartment to sale in lots to the Yeongdeungpo City Mayor, and the wooden City Mayor.