1. As to the Plaintiff (Counterclaim Defendant)’s KRW 800,000,000 to the Defendant (Counterclaim Plaintiff) and its related amount, from April 17, 2018 to October 19, 2018.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On December 14, 2017, the Plaintiff and the Defendant: (a) sold the instant land to the Defendant at KRW 6 billion (hereinafter “instant sales contract”); (b) paid on the date of the contract the remainder of KRW 5.484 billion on the day of the contract; (c) paid the remainder of KRW 5.484 billion on April 16, 2018 (Article 2); and (d) paid a double amount of the down payment at the time of the seller’s breach of contract; and (e) decided to waive the buyer’s down payment (Article 6); and (c) Article 2 of the Special Clause provides that “The seller shall transfer to the Defendant the entire cemetery located on the instant land before the remainder.”

(hereinafter “instant special agreement”). The Defendant paid the down payment to the Plaintiff on the same day.

B. On December 26, 2017, the Plaintiff entered into a contract with D and D providing funeral services as proxy, and agreed that D will not claim excess expenses if the total number of graves exceeds 30 square meters, including expenses for reburials, cremations, cremations, and cremations (i.e., KRW 20,000,000, KRW 1500,000, KRW 20,000, KRW 13,000,000, KRW 20,000, KRW 150,000).

C. Around that time, there was a 57-year funeral for the instant land. However, the Plaintiff, among the 15-year funerals, was subject to the procedures for the public announcement of the reburial of a grave on December 27, 2017 to March 21, 2018, pursuant to Article 27(2) and (5) of the Act on Funeral Services, Etc. (hereinafter “the Funeral Act”) and Article 18(4)2 of the Enforcement Rule of the Funeral Act.

Around March 28, 2018, the Defendant confirmed that there was an additional 40 or more, for about 15 additional days, in addition to the 15th public notice of the instant land. A permission for relocation should be granted only for the 15th term of a publicly announced grave around March 30, 2018 and around April 4, 2018, when the competent administrative agency is Ansan, the permission for relocation should be granted only for the 15 term of a publicly announced grave, and the remaining grave shall undergo the procedures of public announcement as prescribed by the Funeral Act, and shall be thoroughly prevented the Plaintiff from arbitrarily disposing of the grave without going through the procedures.