1. The defendant (Counterclaim plaintiff)

A. The Plaintiff (Counterclaim Defendant) indicated the attached Form 1 drawings among the 48,682 square meters of Gangseo-si forest land in Gangseo-si, and the 141 and the attached Form 1.

1. Basic facts

A. The Plaintiff is the owner of 4,407 square meters (hereinafter “F land”) before Gangnam-si, Gangnam-si, and F land is a franchis with no contribution.

2) On the south of the F’s land, the area adjoining to D previously 3,435 square meters (hereinafter “D”) in the south of the said F’s land. The said area adjoins to D’s land the area of which is 48,682 square meters of forest land (hereinafter “C”) in Gangseo-si, Gangnam-si, and both D’s and C’s land are owned by the Defendant.

3) Not only the above D land and C land but also G 3,314 square meters (hereinafter “G land”), B prior to H, 730 square meters (hereinafter “H land”), E forest land and 7,645 square meters (hereinafter “E land”) were part of C forest land and C land (hereinafter “C land before subdivision”) prior to the original subdivision. The Defendant completed the registration of transfer of ownership of C land prior to the said subdivision on December 10, 207.

4) On March 20, 2018, E and I forest land 577 square meters (hereinafter “I land”), J forest 3,390 square meters (hereinafter “J land”), K forest 1,673 square meters (hereinafter “K land”), 3,270 square meters of L forest 3,270 square meters (hereinafter “L land”), M forest 721 square meters (hereinafter “M land”) are divided in the land B before subdivision, following the same year:

3. 23. J land was d land for D land, L land for G land, and M land was h land for H land, while the remaining 62,360 square meters of forest land in Gangseo-si, Gangnam-si, and the current C land remains due to the division of 13,678 square meters of O forest land on November 14, 2018.

B. 6,542 square meters (hereinafter “N land”) prior to the n of Gangseo-si, Gangnam-si, the Plaintiff, as the land owned by Gangseo-si, was cultivated upon entering into a loan agreement with Gangnam-si from January 1, 2008 (the current term of the loan agreement up to December 31, 2022). The above N land is a package of the land owned by the Defendant, which is used as a road access road to pass a public road as a franchisor, and is indicated in the annexed drawing Nos. 3, 27, 28, 29, 30, 30, 31, 32, 33, 34, and 27.