1. Upon the new claim of the Plaintiff (Counterclaim Defendant) at the trial, the Defendant (Counterclaim Plaintiff) against the Plaintiff (Counterclaim Defendant).

1. Basic facts common to the principal lawsuit and counterclaim;

A. The establishment of the Plaintiff Association and the first reconstruction resolution 1) A1 and the second apartment (hereinafter “instant apartment”) constructed on the land of 392,652 square meters and D large 5,355.3 square meters in Songpa-gu Seoul Metropolitan Government, Songpa-gu, Seoul, and on the ground of 5,355.3 square meters.

The Act on the Ownership and Management of Aggregate Buildings (hereinafter “the Act”) around July 13, 2002, on the Ownership and Management of Aggregate Buildings.

(1) In lieu of the management body meeting at the meeting of the management body, the committee for promotion of A Apartment-Final Equity Holdings (hereinafter “instant committee for promotion”).

(2) On May 24, 2003, the instant promotion committee held an inaugural general meeting of a reconstruction association and submitted a written resolution in lieu of actual attendance or attendance by 4,280 of the total sectional owners of the instant apartment complex, which was subject to rebuilding resolution (hereinafter “the first rebuilding resolution”), approval of the association regulations, approval of the association regulations, a resolution on the method of business, a resolution on the appointment of the president of the association, and a resolution on the selection of the contractor.

3) After that, the Plaintiff Union was established by the first re-building association composed of 5,786 sectional owners including the sectional owners who agreed to the above re-building resolution at the early June 2003, and the Plaintiff Union completed the establishment registration on July 15, 2003 with the approval from the head of Songpa-gu Seoul District Court for the establishment of the association consisting of 5,786 sectional owners, including the sectional owners who agreed to the re-building resolution at the early June 11, 2003. The Plaintiff Union concluded the establishment registration on June 12, 2003 with the approval from the head of Songpa-gu Seoul District Court for the establishment of the 5,786 sectional owners. (b) The Plaintiff Union asserted that the first re-building resolution becomes null and void, and even in the case of Seoul East East District Court Decision 203Gahap5618, Seoul District Court Decision 2003Da5618, Mar. 11, 2004, the first re-building resolution was issued to the sectional owners specifying.