1. On October 17, 2014, the Defendant did not restrict the Plaintiff’s right to real estate stated in the attached list No. 1 list.

1. Basic facts

A. The Plaintiff was authorized to establish an association on June 22, 201 pursuant to the Act on the Maintenance and Improvement of Urban Areas and Dwelling Conditions for Residents (hereinafter “Urban Improvement Act”) in order to implement a housing reconstruction improvement project with Do Borrowing as an improvement zone located in Gangnam-gu Seoul Metropolitan Government (hereinafter “Urban Improvement Act”). The Plaintiff completed the registration of incorporation on July 26, 201 after obtaining authorization to establish an association.

B. The Defendant consented to the establishment of the Plaintiff as the owner of the real estate listed in the attached Table 1 list in the above improvement zone (hereinafter “instant real estate”).

C. After receiving an authorization to implement a project on August 8, 2014, the Plaintiff notified and publicly notified that “the period of filing an application for parcelling-out is from September 16, 2014 to October 16, 2014, and the ordinary square of the building subject to parcelling-out is from 34 square, 62 square, 72 square, 76 square, and 83 square,” and the Plaintiff received an application for parcelling-out from the members during the said period.

On October 16, 2014, the expiration date of the above application period for parcelling-out, the Defendant submitted to the Plaintiff the “scale of the house which wishes to be sold” column of the application for parcelling-out, by stating only the “an ordinary figure corresponding to a free equity ratio” without stating either of the above types.

E. Accordingly, upon receipt of the above application for parcelling-out, the Plaintiff is classified as the object of cash settlement pursuant to Article 47 of the Act on Urban Improvement, if the Plaintiff fails to file a re-application by supplementing the time limit for filing the application for parcelling-out, and thus, the Plaintiff may lose its membership. Accordingly, the Plaintiff notified the Defendant that the Plaintiff would be entitled to a legitimate and effective settlement before the expiration of the expiration date. However, the Defendant did not submit an additional application for parcelling-out until October 16, 201

F. On May 7, 2015, the Plaintiff offered performance several times to the Defendant in order to pay the cash settlement amount of KRW 2.12 billion to the Defendant, on behalf of the Defendant classified as the subject of cash settlement on October 17, 2014 due to the failure to file an application for sale, on the ground that “The Defendant rejected the application.”