1. The Plaintiff:

(a) Defendant A and B real estate listed in Section 1 of the [Attachment 1] list;

(b) the defendant.

1. Basic facts

A. Memerar Construction Co., Ltd. (hereinafter “Memerar Construction”) newly constructed and sold the 1st of the 7th underground and the 20th above ground level on the land outside Jongno-gu Seoul Metropolitan Government H and one parcel (hereinafter “I”), thereby executing the “JB redevelopment project” (hereinafter “instant redevelopment project”).

B. On October 31, 2003, the Military Mutual Aid Association loaned KRW 135 billion to the Rotterdam as business funds for the instant redevelopment project, including I’s construction, between the Rotterdam Construction and the Military Mutual Aid Association (hereinafter “the instant project agreement”) and concluded a business agreement with the content that the amount of the principal and interest on the leased loan and the amount of the business profit of KRW 35 billion is to be paid as a consideration from the Rotterdam Construction (hereinafter “instant project agreement”).

On January 11, 2008, the Military Mutual Aid Association and the Memeral Construction agreed to partially modify the instant business arrangements.

C. On November 20, 2003, the Plaintiff entered into a trust agreement with the Plaintiff on November 20, 2003, stipulating that Memera Construction entrusted all of the instant redevelopment project’s project site and the instant ground buildings to be constructed in the future, but the Military Mutual Aid Association shall be designated as the priority beneficiary of trust principal and trust proceeds (hereinafter “the instant first trust agreement”).

On the other hand, on April 28, 2004, Memerar Construction entered into a fund management agency contract with the Plaintiff and the Military Mutual-Aid Association (hereinafter “instant fund management agency contract”) to determine detailed matters not specified in the I’s business agreement concerning the management of the sales price.

E. On July 27, 2007, the new building was completed and approved by the competent authorities, but at the time Memerat Construction did not pay 17.5 billion won out of 35 billion won of profits under the instant business agreement to the Military Mutual Aid Association.

As a result, Memerar Construction guarantees the remaining obligations of the Military Mutual Aid Association.