1. On the basis of a new claim by the Plaintiff (Counterclaim Defendant) at the trial, the Defendant (Counterclaim Plaintiff) is the Plaintiff.

1. Basic facts common to the principal lawsuit and counterclaim;

A. The Plaintiff is a housing reconstruction association established to implement a housing reconstruction project with A 1, 2, and 1 commercial buildings constructed on the land of 392,652 square meters and D large 5,355.3 square meters of land in Songpa-gu Seoul Metropolitan Government (hereinafter “instant apartment”), and the Defendant is the owner of the real estate in the attached list in the improvement zone of the instant reconstruction project (hereinafter “instant real estate”).

B. The Plaintiff’s establishment and the first reconstruction resolution 1) Some sectional owners of the instant apartment are entitled to the Act on the Ownership and Management of Aggregate Buildings around July 13, 2002 (hereinafter “Aggregate Buildings Act”).

(1) In lieu of the management body meeting at the meeting of the management body, the committee for promotion of A Apartment-Final Equity Holdings (hereinafter “instant committee for promotion”).

(2) On May 24, 2003, the instant promotion committee held an inaugural general meeting of a reconstruction association and submitted a written resolution in lieu of actual attendance or attendance by 4,280 of the total sectional owners of the instant apartment complex, which was subject to rebuilding resolution (hereinafter “the first rebuilding resolution”), approval of the association regulations, approval of the association regulations, a resolution on the method of business, a resolution on the appointment of the president of the association, and a resolution on the selection of the contractor.

3) On June 12, 2003, the Plaintiff received the “Written Agreement for Rebuilding Resolution and Implementation of Projects” with the contents of consent to the first rebuilding resolution from the sectional owners, including the sectional owners who participated in the above inaugural general meeting. On July 15, 2003, the Plaintiff obtained authorization from the head of Songpa-gu for the establishment of a partnership consisting of E and association members with the above 5,786 members. On July 15, 2003, the Plaintiff completed the registration of establishment [the Plaintiff was the “A Apartment Reconstruction Association,” but the name was changed according to the implementation of the Urban and Residential Environment Improvement Act (hereinafter “Urban Improvement Act”) on July 1, 2003, and within one month from the date of enforcement of the Urban Improvement Act.