1. The plaintiff (Counterclaim defendant) is jointly employed by the defendant (Counterclaim plaintiff) for the 81,497,592 won.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Plaintiffs, among the construction works involving the relocation of buildings in Incheon, Seo-gu and F ground G G buildings and the construction of new buildings in the B-dong (hereinafter collectively referred to as the “instant building”), contracted each of the instant wooden construction and interior construction works to the Chief of the Defendant Daesung, the U.S., waterproof and lighting construction to Defendant C, and the electricity, telecommunication, and fire fighting construction to Defendant D.

B. In relation to the above contract, (i) around July 15, 2015, Defendant Daesung Co., Ltd provided a quotation for the calculation of the total construction amount of KRW 240 million based on the materials cost, unit cost, and quantity of labor cost by each of the detailed construction items and the interior construction works; and (ii) around November 13, 2015, reflecting the Plaintiffs’ request for additional construction works, a statement stating the total construction amount of KRW 320 million was provided, but the separate contract for construction works was not prepared between Defendant Daesung Construction and the Plaintiffs.

② Defendant C did not prepare a separate contract for construction works with the Plaintiffs, and provided a written estimate with the content that calculated the total construction amount of KRW 145,144,720 based on the detailed materials cost, unit price, quantity, etc. for each of the items of construction work, and labor cost for each of the following items.

③ On May 24, 2015, Defendant D entered into a contract with the Plaintiffs regarding construction cost of KRW 40 million in relation to electricity, telecommunications, and fire fighting construction works.

C. On the other hand, Defendant C and the Plaintiffs agreed to exclude the waterproofing construction and the Roof Bomproof construction from the floor of the parking lot among the detailed construction items of the estimates provided by Defendant C. The construction cost based on the said estimates, excluding this, is KRW 128,883,720.

② Defendant D paid 2,400,000 won for communications certificate necessary for the completion of the building of this case on behalf of the Plaintiffs, separate from the construction project to be performed under the said construction contract.

The Plaintiffs are part of the construction cost to be paid to the Defendants.