A. On May 2015, the Plaintiff purchased five parcels, including 2,297 square meters, D forest land, and 3,079 square meters (hereinafter collectively referred to as “Plaintiff-related land”). At that time, Nonparty E purchased each of the five parcels, including 5,165 square meters, G field 651 square meters, H field 1,29 square meters (hereinafter referred to as “E-related land”).

B. After that, the Plaintiff purchased 249 square meters (75 square meters) out of 13,554 square meters of I forest in Gyeyang-gu, Seoyang-gu, Seoyang-gu (hereinafter “the instant forest before division”) adjacent to the land under the Plaintiff’s name for the purpose of opening access roads to the existing roads, which are installed from the land related to the name of the E via the land related to the name of the E, and completed the registration of transfer of shares in the Plaintiff’s name on September 9, 2015 with respect to the shares of 249/13,554 out of the said forest as of September 7, 2015.

C. On October 2015, E provided the land under the name of E as collateral and took out a loan of KRW 1.65 million from the Defendant to the debtor as the J, and provided the Plaintiff’s share in the forest of this case prior to the division under the Defendant’s consent (the Plaintiff appointed E as the administrator of the Plaintiff’s share out of the said forest in a loan transaction with the Defendant) at the request of the Defendant, and on October 12, 2015, with respect to the Plaintiff’s share in the said forest of this case, the registration of creation of a neighboring mortgage (hereinafter “registration of establishment of a neighboring forest of this case”) was completed as to the debtor’s share in the said forest of this case on October 12, 2015.

In the process of establishing the instant right to collateral security, the head of the credit team E and the Defendant’s credit team leader K prepared a letter of confirmation that “I will receive the Plaintiff’s share among the forest land in the instant case before division as collateral and will make a promise to terminate the instant right to collateral security upon the completion of new road registration” (hereinafter “instant letter of confirmation”).

E. The Plaintiff is respectively named in the name of the Plaintiff and E from Gyeyang-gu office in Gyeyang-gu.