1. The Plaintiff (Counter-Defendant) indicated the annexed map No. 1, 2, 3. of the annexed map No. 3,164 square meters among the land size No. 3,164 square meters in Seongbuk-gu, Sungnam-si.

1. Basic facts

A. The instant real estate was owned by the Plaintiff. The Defendant and E acquired 1/2 shares of each of the above site during the voluntary auction procedure on June 26, 2012, and the ownership of the above ground housing was also acquired.

B. The ditch of this case is the real estate owned by the country adjacent to the real estate of this case, and the plaintiff obtained permission to occupy and use the above ditch from the Sungnam-si Office from May 2001.

C. On August 6, 2012, the Plaintiff, through the wife F, prepared a letter of undertaking as shown in the attached Form, in the course of delivering the instant real estate to the Defendant on August 6, 2012 between the Defendant and E.

(hereinafter “this case’s declaration”). 【No dispute over the grounds for recognition”, the entries in Gap’s Evidence Nos. 1 through 4, 7, 8, and 10, and the purport of the whole pleadings

2. The parties' assertion

A. Although the Plaintiff continued to pay the fees and license tax since the Plaintiff obtained permission to occupy and use public waters around May 2001 from the Seongbuk-gu Office of Branch of Branch of Branch of Branch of Branch of Branch of Branch of Branch of Branch of Branch of District Office, the Defendant occupied them without justifiable cause and prevented the Plaintiff from harvesting crops, thereby causing damages to the following contents. Thus, the Defendant is obligated to collect each product stated in the purport of the claim on the said ditches from the Plaintiff, deliver the said ditches, and compensate for damages as set forth below.

원고가 입은 구체적 손해는, 피고가 이 사건 구거를 불법 점유한 2012. 9. 1.부터 1년 10개월 상당의 기간 동안 원고가 납부한 사용료 484,494원과 면허세 49,499원 등 합계 531,499원, 피고의 위 점유기간 동안 원고가 이 사건 구거에서 더덕, 참나물, 깻잎, 대봉감 등을 매년 경작하였다면 얻었을 것으로 보이는 5,499,990원, 원고가 2014. 5. 10. 이 사건 구거에 고구마 100포기를...