1. The instant lawsuit shall be dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

Plaintiff’s assertion

On August 16, 2016, the Plaintiffs and the Defendant agreed to include the AV apartment 20,21 units and 21 units, which were partially partitioned by the Plaintiffs, in the rebuilding objects of the Defendant Union, and agreed to bear the Plaintiffs’ total amount of KRW 3 billion with the design cost, interest accrued from the delay in sale in general (hereinafter “instant integrated development agreement”). At the request of the Defendant Union based on the above agreement, the Plaintiffs paid KRW 50 million per capita to the Defendant Union.

However, among the integration development agreement of this case, the plaintiffs paid 3 billion won to the defendant association is conditioned that the integrated development would cause losses to the defendant association, and there was no loss due to the integrated development.

In addition, although the defendant union did not expect losses due to the integration development of this case, the plaintiffs caused losses of 63 billion won due to the integration with the plaintiffs, and thus, the plaintiffs deceivings the plaintiffs that the plaintiffs should bear the 3 billion won of such losses, and the plaintiffs did so, thereby making the agreement on the integration development of this case with the defendant union.

Therefore, the instant integrated development agreement should be revoked on the ground of deception or mistake, and even if not, according to the instant integrated development agreement, the burden of the Plaintiffs’ 3 billion won is a method of deducting the Plaintiffs’ rights from the amount of money, and it is not a method of directly paying to the Defendant Union.

Therefore, the defendant union is obligated to return to the plaintiffs the amount of KRW 50 million already received as unjust enrichment.

The judgment of the court on the main defense against the main defense was made by the plaintiffs and the defendant, and thus, the lawsuit of this case is unlawful against the non-committee agreement.

According to the statement in Gap evidence No. 6, the plaintiffs and the defendant union raise an objection against each other after preparing a joint development agreement.