1. The Plaintiff (Counterclaim Defendant) paid KRW 297,658,738 to the Defendant (Counterclaim Plaintiff) and its amount from March 28, 2017 to August 10, 2017.

A principal lawsuit and a counterclaim shall be deemed to be combined.

1. Basic facts

A. On August 20, 2013, the Plaintiff entered into a contract with Defendant D, E, and C for the construction of the Gangseo-gu Seoul Metropolitan Government, G, and H ground I building (hereinafter “instant new building”) (hereinafter “instant construction”) with the amount of KRW 9,265,438,60 (including value-added tax) on August 26, 2013 as of the commencement date of the construction work, and on December 31, 2014, the completion date of the completion of the construction work. Since the project site of the instant construction has been expanded to 12 parcels outside the Gangseo-gu Seoul Metropolitan Government, the Plaintiff changed the contractor to Defendant A Co., Ltd. (hereinafter “Defendant A”), and the construction cost shall be KRW 13,952,400,00 (excluding value-added tax) on August 20, 2013, the contract for construction work shall be concluded again.

Around May 2014, Defendant A, Defendant B (hereinafter “Defendant B”), Defendant C, D, and E (hereinafter “Defendant B”), entered into a contract to change the construction cost into KRW 15,200,000 (value-added tax separate), and entered into a contract on November 30, 2014 (hereinafter “instant contract”). On November 30, 2014, the contract again changed the completion date to February 28, 2015 (hereinafter “instant contract”).

B. On February 17, 2015, the Plaintiff and Defendant B drafted an agreement regarding the payment of the remainder of the construction cost of the instant construction project (hereinafter “instant agreement”). The instant agreement contains the following details.

1. Defendant B issued to the Plaintiff a certificate of international trust interest after completion of the instant construction.

2. The Plaintiff submitted all the documents necessary for the completion of the instant construction to Defendant B, and completed all the necessary construction after completion.

3. The cost of construction after construction shall be calculated in quantities.

C. On March 20, 2015, the Plaintiff completed the instant construction and obtained approval for the use of the said new building.

Defendant D, E, C, and Defendant B are the instant case between Korea Trust Co., Ltd. (hereinafter “Korea Trust”) and the Korea Trust Co., Ltd. on or around May 2015.