(a) deliver the real estate listed in the separate sheet;

(b) 106,971,889 won and any objection thereto;

A. As to the instant real estate, C completed the registration of ownership preservation on May 3, 1989, and D completed the registration of ownership transfer on the ground of testamentary gift on February 27, 2009, and A completed the registration of ownership transfer on May 7, 2019.

B. On April 15, 2006, E, the Defendant’s spouse, entered into a lease agreement with C by setting the lease deposit of KRW 25 million, monthly rent of KRW 600,000, and the lease term of KRW 24 months from April 15, 2006.

On April 15, 2009, the Defendant entered into a lease agreement (hereinafter “instant lease agreement”) with F on April 15, 2009, setting the lease deposit amount of KRW 25 million, monthly rent of KRW 600,000,000, and the lease period of KRW 24 months from April 15, 2009.

C. However, around June 2009 and around July 2009, D asserted that the instant lease agreement entered into with F was null and void as it was concluded with a person without any authority and notified him/her that it will be delivered to him/her on several occasions.

D and F are children of C. D. H.

D and its brothers and sisters had a dispute over the inherited property of C including the fourth floor building in Ulsan-gu G located in the Republic of Korea for about 10 years from around 2009 to around 2019, including the fourth floor of the building including the instant real property.

E. D around April 30, 2019, from April 15, 2009, the Defendant occupied and used the instant real estate without any title, transferred the right to claim restitution of unjust enrichment to the Plaintiff. Around May 1, 2019, the Defendant notified the transfer to the Defendant.

F. As to the instant real estate, the sum of the ordinary rent of KRW 25 million, which is not considered from June 7, 2009 to September 30, 2019, is the sum obtained by deducting the rent from the assessed value of KRW 116,137,932 to June 6, 2009, which is the day before the instant lawsuit was filed, from the assessed value of KRW 116,137,932, and adding the tea from May 17, 2019 to September 30, 2019.

The monthly rent for the instant real estate is from April 15, 2009.