2. The costs of appeal shall be borne by the Defendant.

Purport of claim and appeal

1..

The Defendant publicly announced the bid for loan property on November 13, 2015 through reclamation of public waters, completed each registration of initial ownership on each of the real estate listed in the separate sheet (hereinafter “each of the instant land”) newly registered on November 13, 2015.

On September 15, 2017, the Korea Asset Management Corporation entrusted the management of each of the instant lands by the Defendant, and publicly announced the loan bid (hereinafter “instant bid”) by setting the first scheduled value as KRW 177,254,000 with respect to each of the instant lands at KRW 177,254,00.

On November 28, 2017, the Plaintiff participated in the instant bidding and was selected as a successful bidder. On November 28, 2017, the Plaintiff concluded a loan agreement with the terms that the Plaintiff would receive a loan from the lessee for the purpose of using each of the instant land as a fishing place, setting the loan period from the lessee from November 28, 2017 to November 27, 2022, with the annual loan rate of KRW 92,100,000 (excluding value-added tax) (hereinafter “instant loan agreement”).

The above contract is written by the defendant (the Ministry of Strategy and Finance) and the Korea Asset Management Corporation as the trust institution of the lender, respectively.

On November 28, 2017, the Plaintiff paid to the Korea Asset Management Corporation a sum of KRW 101,310,000,000 (i.e., rent KRW 92,100,000, value-added tax amounting to KRW 9,210,00) as stipulated in the instant loan agreement.

On March 14, 2018, the Urban Planning Committee of Chungcheongnam-do, the Plaintiff’s notification of the cancellation of the instant loan agreement and the return of the loan charges of Korea Asset Management Corporation designated the purpose of use of each of the instant land as a production management area and notified it in ASEAN. As a result, the Plaintiff was unable to obtain permission for a fishing place on each of the instant land, and the Plaintiff requested the Korea Asset Management Corporation to terminate the instant loan agreement on August 2, 2018.

Accordingly, the Korea Asset Management Corporation notified the Plaintiff of the termination of the instant loan agreement as of September 3, 2018, and the Plaintiff was at KRW 92,100,000 paid by the Plaintiff.