1. The Defendant-Counterclaim Plaintiff (Counterclaim Defendant) indicated the annexed map No. 1, 2, 3, 4. among the annexed map No. 1, 2, 3, 4.

1. Basic facts

A. On May 26, 1992, the Plaintiff completed the registration of ownership transfer on the ground of the division of co-ownership with respect to the land of Gyeyang-gu, Seoyang-gu (hereinafter “instant land”). After completing the registration of ownership transfer on the ground of the division of co-ownership, the Plaintiff constructed and installed a single-story house of 70 square meters (hereinafter “instant house”) and a vinyl house, etc. on the ground of the instant land.

B. As to the land of this case, D Union completed the registration of creation of a mortgage on September 30, 1998, consisting of the debtor 28,800,000 with the maximum debt amount of Sep. 30, 1998, and the establishment of a mortgage on Nov. 3, 200 with the maximum debt amount of Nov. 3, 200.

C. On June 27, 2003, the Plaintiff completed the registration of ownership transfer for the instant land to E, and on July 28, 2003, the debtor of the registration of ownership transfer for each of the above D unions was changed to E.

After October 21, 2005, D Union completed the registration of creation of a mortgage on the instant land, which is the maximum debt amount of 70,000,000 won for the debtor E, with respect to the instant land.

D Partnership received a decision to commence the sale of real estate as F from the above collective security right on September 4, 2014. At the above auction procedure, the Defendant purchased the instant land and completed the registration of ownership transfer as the receipt of No. 189910 on October 13, 2015, which was 189910, in order to acquire the instant land from the Jung-gu District Court.

F. Although the Defendant applied for an order to deliver real estate against the Plaintiff for the delivery of the instant land and rendered a decision to accept it at the first instance court, the appellate court revoked the first instance court and dismissed part of the Defendant’s claim on the ground that the statutory superficies for the possession of the instant housing is recognized.

(G) On December 15, 2015, G Decision 2016Ra47 dated August 29, 2016, which was rendered by the High Government District Court (Seoul District Court Order 2016Ra47 dated August 29, 2016). The instant housing is constructed on the portion of 70 square meters within the scope of a local government-invested organization located in the ship (hereinafter referred to as “the portion of a local government-invested organization”) which successively connected each of the items of the attached drawings 1, 2, 3, 4, 5, 6, and 1 among the instant land. The Plaintiff is each of the following: (a) the indication of the attached drawings 2, 7, 7, and 7.