2.(a)

On February 13, 2013, Nonparty C performed reimbursement to the Defendant.

A. The Plaintiff loaned money to C from around 2004 to February 2012. Around February 20, 2013, the remaining claims between C and C were determined as KRW 366,60 million. On July 16, 2013, the Ulsan District Court filed a lawsuit against C on the claim for loans amounting to KRW 2013Gahap4919, and on August 14, 2014, “C pays to the Plaintiff the amount calculated at the rate of KRW 360,000 and KRW 20% per annum from August 22, 2013 to the date of full payment” (hereinafter the instant judgment), which became final and conclusive as is.

B. The registration of creation of a right to lease on a deposit basis, which is 270 million won of the maximum debt amount, was completed for the real estate indicated in the attached list, which was owned by C (hereinafter “the instant real estate”), and the Defendant’s registration of creation of a right to lease on a deposit basis, which is 270 million won of the maximum debt amount, for the establishment of a right to lease on a deposit basis (hereinafter “right to lease on a deposit basis”), was completed.

C. On February 13, 2013, C paid KRW 70 million to the Defendant for the repayment of the secured obligation of the instant right to collateral security (hereinafter “instant repayment”) and revoked the registration of establishment of the instant neighboring mortgage.

At the time of the instant repayment act, the instant real estate was the only real estate of C, and was in excess of debt due to the Plaintiff’s debt, etc.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 4, and 5, the purport of the whole pleadings

2. Main claim;

A. The Plaintiff’s assertion C concluded a loan agreement for consumption with the Defendant to set up the instant right to collateral security without bearing any obligation against the Defendant, and the instant repayment act also follows an invalid loan agreement. Therefore, the Defendant shall return the instant repayment amount to C as unjust enrichment.

The plaintiff, as a creditor of C, exercises the right to claim the return of unjust enrichment as C.

B. The Defendant’s defense prior to the merits is exercising C’s right to receive some money from the Defendant.