1. The Plaintiff (Counterclaim Defendant) paid KRW 286,00,000 to the Defendant (Counterclaim Plaintiff) and its related amount from July 1, 2007 to May 26, 2016.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On September 6, 2002, the Plaintiff entered into a contract with D (hereinafter “D”) to sell the purchase price of KRW 2,860,000,000 (hereinafter “instant land”) to the Plaintiff’s KRW 3,792 square meters prior to the E-si, Young-gu, Young-gu, Young-si and KRW 3,792 square meters prior to the date of the change of the name of the administrative district after the change. On May 12, 2012, the Plaintiff: (a) divided the land into KRW 2,547 square meters prior to the Kuung-gu and KRW 1,245 square meters prior to the date of the change of the name of the administrative district; and (b) concluded a contract to sell the land to KRW 2,8

The plaintiff received 286,00,000 won as down payment, and the remaining 2,574,000,000 won was paid on April 7, 2003.

B. On April 9, 2003, D requested the Plaintiff to extend the remaining payment date by June 30, 2003, and on July 2, 2003, D again requested the Plaintiff to extend the remaining payment date by December 31, 2003.

C. On March 28, 2006, the Plaintiff and D entered into a re-contract after changing the purchase price and the payment date of the above sales contract. The Plaintiff and D agreed to pay the remainder of KRW 3,843,00,000, excluding the remainder of KRW 286,000,000,000.

On February 26, 2007, the Defendant and D entered into a contract for the transfer of the apartment site with the content that the Defendant would purchase the site for the new apartment construction project implemented D at the Japanese Won including the instant land, etc.

E. Meanwhile, there is a sales contract (No. 2; hereinafter “instant sales contract”) prepared around June 2007, stating that the Plaintiff would sell the instant land to the Defendant in the purchase price of KRW 4,473,573,00 (the payment of KRW 286,00,000, the balance of KRW 4,187,573,000, and the time when trust documents are submitted).

F. On April 8, 2009, the Plaintiff donated the instant land to G, H, and I, who is the Plaintiff’s child, and G, H, and I completed the registration of ownership transfer on April 17, 2009 for the instant land based on a donation made on April 8, 2009.

G. G, H, and I shall be October 19, 2015.