A. On October 11, 200, the Plaintiff and his children, C, and D, respectively, shall inherit the 3/7, 2/7, 2/7, and 2/7 shares of the building on the land and 231.7 square meters and its ground (hereinafter collectively referred to as “instant real estate”) in Gwangjin-gu Seoul Special Metropolitan City, Seoul, and complete the registration of ownership transfer.

B. Around 2007, G had a claim for the construction cost equivalent to KRW 90 million against C. However, the Defendant acquired the claim for the said construction cost from G, and completed the registration of creation of a neighboring mortgage covering KRW 117 million with respect to the share owned by C among the instant real estate on July 5, 2007, in order to secure the said claim for the construction cost.

C. Around 2009, G had a claim for the construction cost of KRW 480 million in addition to the above construction cost claim against C. However, the Defendant acquired the above construction cost claim of KRW 480 million from G in addition to the above construction cost claim.

On January 1, 2010, C and the Defendant settled the amount to be paid by C to the Defendant as KRW 600,000,000, and promised to set up a right to collateral security with respect to C owned shares and D owned shares out of the instant real estate.

However, unlike the above promise, C requested the Defendant to lend the above money in addition to the amount of KRW 55 million when it was not set up the right to collateral security, and the Defendant agreed to lend the above money if it was set up the right to collateral security in accordance with the above promise.

E. Accordingly, C borrowed KRW 26 million from the Defendant on April 6, 2011, and completed the registration of creation of a neighboring mortgage covering KRW 300 million with respect to the portion owned in the instant real estate as the maximum debt amount. On June 7, 2011, C borrowed additional KRW 29 million from the Defendant, with D’s consent, and completed the registration of creation of a neighboring mortgage covering KRW 200 million with respect to the portion owned in the instant real estate as the maximum debt amount (hereinafter “registration of creation of a neighboring mortgage”).

F. After that, C was unable to repay the above loans to the Defendant on August 2012.