1. The Defendant (Counterclaim Plaintiff) shall:

A. Each land listed in the separate sheet No. 1 and each land above to Plaintiff (Counterclaim Defendant) A.

A principal lawsuit and counterclaim shall also be deemed a principal lawsuit and counterclaim.

1. Common factual relations;

A. Each of the lands listed in the separate sheet Nos. 1, 2, and 3 (hereinafter collectively referred to as “each of the instant lands”) and each of the buildings listed in (c), (d), and (f) (hereinafter referred to as “instant building”) was owned by E, the father of the Plaintiffs.

B. From around 1975, E: (a) between F, the Defendant’s father, and F, while residing in the instant building, F, while developing and operating each of the instant land as an orchard by planting fruit trees; (b) on the other hand, E bears the expenses for the development of the instant orchard; and (c) entered into a contract with F to pay wages in return; (d) around that time, F commenced construction of orchard, such as clearing each of the instant land and planting pine trees.

Around 1979, the Defendant entered into a contract with E with the foregoing contents, and started the construction work of orchard together with F.

(hereinafter referred to as “instant contract”) E, F, and the Defendant’s contract.

F and the Defendant: (a) developed each of the instant land, planted trees, and completed the development of orchard around 1980; and (b) began to harvest fruit trees from 1981.

However, since around 1981, E did not pay F and the Defendant the expenses or benefits necessary for the operation of the orchard, and F and the Defendant did not give E the profits, etc. accrued while operating the orchard.

Since then, E returned to Korea after completing his overseas service, but did not pay any attention to the above orchard, and F and the Defendant were also operating the above orchard independently without the interference of E as before.

On the other hand, F died around 196, and after then, the defendant was able to do so.