1. The Plaintiff (Counterclaim Defendant)’s main claim against the Defendants and the Defendant (Counterclaim Plaintiff) and the Defendant (Counterclaim Plaintiff).

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Defendants’ exercise of their right of retention 1) Q (hereinafter “ Q”) Co., Ltd.

(2) On May 20, 2008, the Seoul Special Metropolitan City Gwangjin-gu R Apartment Co., Ltd. (hereinafter “instant 703”), in lieu of the payment of some part of the construction cost as the interior of the R apartment of the Seoul Special Metropolitan City, Gwangjin-gu, Seoul Special Metropolitan City R apartment Co., Ltd., on February 15, 2007 (hereinafter “R apartment”).

The registration of transfer of ownership in Q’s name was completed, and R apartment Nos. 702 (hereinafter “instant Nos. 702”) on the same day. In addition to the instant Nos. 702 and 703, each of the instant apartment units is “each of the instant apartment units.”

2) On November 6, 2008, the Seoul Eastern District Court rendered a decision to voluntarily commence the registration of ownership transfer under the name of Q Q’s representative director, and U as to the instant 702.

3) In each of the above voluntary auction procedures, 33 creditors of Q, including the other Defendants, entrusted Q with the storage of each of the instant apartment units from June 2008 to the Defendant P for the possession and management of the said apartment units, by asserting that, even though the construction was subcontracted from Q on February 6, 2009 and completed the construction, the construction was not paid a total of KRW 760,822,729, and that each of the instant apartment units was jointly occupied.

5) Meanwhile, the rest of 17 and 13 construction creditors of Q around February 2009, from among the rest of the Defendants, filed a payment order with the Seoul Eastern District Court 2009Guj1779 against Q, and with the Seoul East Eastern District Court 2009Guj1046 against Q, claiming payment of the total amount of KRW 731,576,379 except the amount of credit of the Defendant New L&D, and delayed payment damages therefor, and each of the above payment orders became final and conclusive on March 19, 2009.