1. The plaintiff (appointed party, counterclaim defendant) and the selecter (Counterclaim defendant) are listed in the attached list to the defendant (Counterclaim plaintiff).

1. The Plaintiffs, as the successors of the network D (hereinafter “the deceased”), completed the registration of ownership transfer on April 9, 2019 with respect to the real estate listed in the separate sheet (hereinafter “instant real estate”) on April 9, 2019, by one-fourths each due to inheritance by agreement and division as of September 25, 2017.

On July 18, 1996, the Defendant entered into a promise to sell and purchase the instant real estate (hereinafter “the instant promise”) with the Deceased as follows, and completed the provisional registration of the right to claim transfer of ownership (hereinafter “the instant provisional registration”) on November 15, 1996 with respect to the instant real estate on the ground of the instant promise to trade.

Article 1 The Deceased has promised to sell the real estate of this case to the Defendant in price of KRW 70,00,000,000, which shall be accepted by the Defendant.

Article 2 The date of the completion of the sale and purchase contract shall be June 30, 1997, and the sale and purchase contract shall be deemed to have been completed as a matter of course without the defendant's declaration of intention to complete the sale and purchase.

When the sale and purchase has been completed pursuant to Article 3(2), the sale and purchase contract for the above real estate between the deceased and the defendant shall be concluded, and the deceased shall receive the price under Article 1 from the defendant, and shall, at the same time, implement the procedure for the registration of ownership transfer due to the sale and purchase of the above real

Article 4 The defendant shall pay 70,000,000 won on the date of the reservation to the deceased as the deposit money of this reservation, and the amount shall be deducted from the price under Article 1.

[Ground of recognition] Facts without dispute, Gap evidence No. 1, Eul evidence No. 2, the purport of the whole pleadings

2. The parties' assertion

A. Although the Defendant exercised the right to complete the pre-sale agreement within 10 years from November 15, 1996, it failed to exercise the right to complete the pre-sale agreement, which is the right to form within 10 years from November 15, 1996, and the exclusion period has expired, the provisional registration

B. The Defendant’s resolution on the completion of a pre-sale agreement under Article 2 of the instant sales contract.