1. The Plaintiff (Counterclaim Defendant)’s conjunctive claim against the Defendant (Counterclaim Plaintiff) added by this Court.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The parties’ relevant Defendant B Co., Ltd. (hereinafter “Defendant Co., Ltd.”) are stock companies with the objective of implementing general buildings, etc., and Defendant C was a representative director of the Defendant Co., Ltd. from April 24, 2014 to February 21, 2018.

B. On October 29, 2012, the Plaintiff transferred KRW 50,000,000 to the account in the name of D, a director of the Defendant Company, on October 29, 2012. On November 8, 2012, the Plaintiff completed the registration of the transfer of shares of KRW 512/2,707, out of KRW 2,682, U.S. forest land owned by the E-owned on November 8, 2012.

2) On October 21, 2013, the FY 2,682 square meters of the FY 2,682 square meters of the land of this case was divided into 505 square meters of F forest land, 505 square meters of H forest land, 512 square meters of J forest land, 99 square meters of J forest land, 161 square meters of K forest land (hereinafter referred to as “redivision, but only once the forest land is divided, but only the land of this case is marked as “instant land”). On October 25, 2013, the Plaintiff completed the registration of transfer of ownership based on the division of co-owned property.

(c)

On November 14, 2013, Defendant C obtained a loan of KRW 800,000,000 from N Cooperatives (hereinafter “the first loan”); in order to secure the said loan, Defendant C had completed the registration of the establishment of a joint collateral mortgage (hereinafter “the first joint collateral mortgage”) with respect to some portion of the instant land and Fland 505m2, J forest 512m2, K forest 161m2, the maximum amount of the claim with respect to the instant portion of the amount of 1,040,000,000, and the debtor C’s joint collateral mortgage (hereinafter “the first joint collateral mortgage”).

(d)

On November 19, 2013, the Plaintiff entered into an agreement with the Defendant Company to receive consulting services in relation to the construction of a building on the instant land. According to the said agreement, the construction cost is KRW 200,000,000 (per square), gas construction cost is KRW 9,00,000, and the cost of civil and construction design is KRW 7,000,000.

E. The second loan and the second joint collateral security 1) Defendant C is an O union on May 16, 2014 (hereinafter “O union”).