1. The Defendant (Counterclaim Plaintiff) against the Plaintiff (Counterclaim Defendant)

(a) Attached Form 2 of the land listed in Annex 1 List 1.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On May 27, 2016, the Plaintiff, via the Plaintiff’s representative director C, concluded a sales contract to sell the land listed in paragraph (1) of the attached Table 1 (hereinafter “land 1”) owned by the Plaintiff to the Defendant for KRW 2,625,00,000 (hereinafter “first sales contract”), and received KRW 500,000,000 as the date of the contract, and the first intermediate payment of KRW 30,000,00 as the first intermediate payment of KRW 2,00,00 on August 29, 2016, respectively, as the intermediate payment of KRW 40,00,000,000, which is part of the down payment, from the Defendant on the same day, under the pretext of the intermediate payment of KRW 10,00,000,000 on July 10, 206, 209, respectively.

B. On September 1, 2016, the Plaintiff entered into a sales contract with the Plaintiff and Nonparty D and E’s joint ownership (hereinafter “second-party land”) to sell KRW 1,460,00,000 to the Defendant via the Plaintiff’s representative director C (hereinafter “second-party sales contract”) and received KRW 150,000,000 from the Defendant on the date of the contract, intermediate payment of KRW 810,000 on the date of the contract, and the intermediate payment of KRW 810,00,000 on December 20, 2016. The Plaintiff received each payment on May 20, 2017, and received KRW 150,000,000 as the down payment from the Defendant on the same day.

C. The Defendant is an executor who carried out the “business of constructing and selling a newly-built and selling a private-use F detached house” on the land, etc., and upon obtaining a building permit from the Kannam-si Office at the time of each of the above sales contracts, and commenced construction works from the end of July 2016.

The second intermediate payment payment of KRW 300,000 has not been paid upon the expiration of the second intermediate payment payment. The second intermediate payment of KRW 810,000 has not been paid upon the expiration of the second intermediate payment payment payment of KRW 810,000 as well as the last intermediate payment of KRW 810,000. Accordingly, the Plaintiff sent a certificate of the content that the Plaintiff sent the notice of overdue payment of the unpaid payment on July 5, 2017 and August 10, 2017 to the Defendant.