1. The Defendant: (a) KRW 15,302,208,040 for the Plaintiff and 6% per annum from May 5, 2015 to January 13, 2017; and (b) January 14, 2017 for the Plaintiff.

1. Basic facts

A. On November 28, 2007, the Defendant entered into an implementation agency contract with C (hereinafter “C”) and the Defendant’s urban development project (hereinafter “instant development project”) to smoothly carry out the urban development project promoted by the Defendant (hereinafter “instant development project”) (hereinafter “instant implementation agency contract”).

The execution agency contract of the instant case includes the agreement entered into between the Defendant and D Co., Ltd. (hereinafter “D”) in 2006 and the execution agency contract of the instant case to serve as a loan, etc. of funds necessary for the instant development project, and when the Defendant redeems C’s loan, it shall be paid in kind from Incheon Metropolitan City after authorization of land substitution plan is granted by Incheon Metropolitan City.

The main contents of the execution agency contract of this case are as shown in the attached Form.

B. C’s lending to the Defendant was granted a loan from A (hereinafter “A”) and lent money to the Defendant. On November 16, 201, the Defendant issued a “certificate of deposit for loan” to confirm that the amount loaned by C to the Defendant after the instant implementation agency contract was KRW 20,302,208,040.

C. C’s default on obligations and the Defendant’s notice of termination on March 22, 2011: (a) written performance letter stating that “The amount of KRW 500 million out of the three-time payment of metropolitan transport facility charges (1,826,713,500) shall be deposited on March 21, 201 and the shortage of KRW 1,326,713,50 shall be lent until April 29, 201” shall be written to the Defendant; (b) however, the Defendant failed to lend KRW 830,000,000 by August 22, 2011.

On July 19, 2011, the Defendant notified the development project of this case along with the “Fund Disbursement Plan according to the Schedule and Promotion Plan for the future of the Cooperatives,” and requested the payment of the borrowed money for seven months after establishing a funding plan so as not to cause any trouble in the development project of this case.

C on August 2, 2011