1. The Defendant (Counterclaim Plaintiff) against the Plaintiff (Counterclaim Defendant)

(a) deliver the real estate listed in the annex;

(b) from April 13, 2010.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On September 17, 2004, the real estate stated in the attached Form (hereinafter “the apartment of this case”) was an apartment that was used as a rental apartment and was planned to be converted for sale in lots around 2009, after being registered as a preservation of ownership in the future of the Korea Land and Housing Corporation (former Korea Housing Corporation).

Upon becoming aware of such circumstances, C agreed to sell the apartment in the name of the Plaintiff between the Plaintiff and the non-resident at the time. Accordingly, the Plaintiff first leased the apartment in this case from the Korea Land and Housing Corporation and completed the move-in report on November 24, 2009.

B. On January 6, 2009, C entered into the instant apartment sale contract with the Korea Land and Housing Corporation under the name of the Plaintiff, and paid the sales price after obtaining a loan of KRW 97 million from the Korea Land and Housing Corporation under the name of the Plaintiff on January 8, 2010. As to the instant apartment, C completed the registration of creation of a neighboring mortgage with the Korea Land and Housing Corporation as a mortgagee on the same day after completing the registration of ownership transfer on January 13, 2010.

C. On the other hand, on February 1, 2010, the Defendant drafted a lease contract with the lease deposit amount of KRW 50 million for the instant apartment, from April 13, 2010 to April 13, 2012. At the time C signed a lease contract with the lease term from April 13, 2010 to April 13, 2012, on which the Plaintiff’s name was inscribed and sealed in the lessor’s column of the said lease contract.

(hereinafter “instant lease agreement”). The Defendant was handed over the instant apartment on April 13, 2010, and filed a move-in report on April 14, 2010, and received a fixed date.

On April 2, 2012, the Defendant filed a lawsuit against the Plaintiff for claiming the return of the lease deposit (Jin-gu District Court 2012Kadan13825). The Plaintiff asserted that C had concluded the instant lease agreement without the right of representation and denied the seal affixed on the lease agreement. The Defendant withdrawn the lawsuit on August 6, 2013 in which the said judgment is pending.

E. The Plaintiff around December 2017, C.