1. The Plaintiff (Counterclaim Defendant) paid KRW 10,000,000 to the Defendant (Counterclaim Plaintiff) and against this, from October 17, 2013 to September 30, 2015.

1. Basic facts

A. On June 8, 2009, C and the Defendant were corporations established on April 21, 2004 with a view to 30,433 square meters in the name of friendly development, the right to permission for quarrying, the right to occupy and use a small river (hereinafter “instant quarrying permission right, etc.”) and all of the offices and equipment owned by friendly development (hereinafter “facilities of this case”) among the 30,433 square meters in the name of Gyeong-do, Ulsan-do, Ulsan Special Metropolitan City (hereinafter “Do forest”).

(E) The Defendant transferred the instant forest to E (hereinafter “E”) and entered into a partnership agreement with the content that the ownership of the instant forest is transferred to E by subrogation of each secured obligation of each of the respective secured rights of collateral and provisional registration established on the instant forest and land, and that the Defendant would jointly operate the instant forest and land and distribute profits therefrom.

B. On June 2009, the Defendant paid a total amount of KRW 950 million for the secured obligation of each of the secured claims and provisional registration security rights established on the instant forest, and completed the registration of ownership transfer in the name of the Defendant regarding the instant forest.

C around September 2009, the title of the instant quarrying permit, etc. was changed to E, and the instant facilities were relocated to E.

C. Around June 2009, around 5,009, C received 2,500 shares, 50% of the total outstanding shares of E, and 2,500 shares, the remainder of which is 50% by the Defendant, respectively.

In addition, F designated by C and the Defendant assumed office as the co-representative of E on June 24, 2009, and F thereafter resign from the office of co-representative on September 28, 2009, the Defendant becomes the representative of E solely from that time.

The defendant around February 17, 2011, the representative director of G was J, the wife of H at that time.

Between the division, the Defendant’s shares and management rights of the E owned by the Defendant and the forest land of this case are KRW 1.7 billion.