1. The Plaintiff:

A. Defendant B received KRW 176,00,000 from the Plaintiff and simultaneously entered in Section 1 of the attached Table.

1. Basic facts

A. In accordance with the Act on the Maintenance and Improvement of Urban Areas and Dwelling Conditions for Residents (hereinafter “Urban Improvement Act”), the Plaintiff is a housing reconstruction project association that obtained authorization from the head of Gangnam-gu Seoul Metropolitan Government on September 1, 2014 and completed registration of incorporation on October 2, 2014.

B. Within the aforementioned project implementation scheduled zone, Defendant B owns the real estate listed in paragraph (1) of the attached Table No. 1 (hereinafter “instant real estate”); Defendant C owns the real estate listed in paragraph (2) of the attached Table No. 2 (hereinafter “instant real estate”); Defendant D owns one-third of the real estate listed in paragraph (3) of the attached Table No. 3 (hereinafter “instant third real estate share”); and Defendant D owns each of the real estate listed in the attached Table No. 1 and 2 together with the instant real estate.

C. On November 7, 2014, the Plaintiff notified the Defendants to reply to whether to consent to a reconstruction project, along with a written consent to the establishment of a housing reconstruction association, stating the amount of expenses for removal of buildings and the amount of expenses to be borne by the Plaintiff, and if there is no reply within two months, the Plaintiff sent a peremptory notice to the Defendants that he/she would exercise the right to demand sale of each real estate owned by the Defendants pursuant to Article 39 of the Urban Improvement Act (hereinafter “the first peremptory notice”) on the ground that he/she did not appear. The Plaintiff again sent the same peremptory notice to Defendant C on December 16, 2014, and the Defendant B on December 24, 2014 (hereinafter “the second peremptory notice”), but the same notice was returned to Nonparty C on December 24, 2014, and on December 24, 2014, the Plaintiff sent the same notice to Nonparty D’s children to Nonparty 1, the Plaintiff’s children and Nonparty 1, Nonparty 3, 2014.

On March 6, 2015, the Plaintiff gave consent to the establishment of a reconstruction association to the Defendants by serving a duplicate of the instant complaint.