A. On September 5, 2013, the Defendant: (a) purchased each real estate listed in the separate sheet (hereinafter “instant real estate”) from the Plaintiff as the purchase price of KRW 360 million; (b) intermediate payment of KRW 15 million; (c) KRW 200 million; and (d) the remainder of KRW 325 million (hereinafter “instant sales contract”); (c) out of the remainder of the special agreement, 200 million is substituted by accepting the secured debt of each right to collateral (excluding the Plaintiff’s acquisition of the Defendant’s obligation to return the lease deposit for the instant real estate (excluding the four floors and 301); and (d) agreed that the Plaintiff will substitute the lease deposit for the lease deposit for the fourth floor and 301 out of the instant real estate leased by the Defendant.

B. In the instant sales contract, the Defendant agreed to pay the Plaintiff and the down payment on the day of the contract, the intermediate payment on September 10, 2013, and the remainder KRW 25 million on October 30 of the same year, respectively, and paid the said down payment to the Plaintiff on the day of the contract, and the intermediate payment on September 9, 2013, respectively.

C. On January 20, 2014, the Defendant filed a lawsuit against the Plaintiff seeking implementation of the procedure for ownership transfer registration on the instant real estate as the cause of the instant sale.

(A) On September 30, 2014, the lower court rendered a judgment that “The Plaintiff shall pay KRW 25,000,000 to the Defendant for the registration of ownership transfer due to the instant sale of the real estate at the same time,” and the Plaintiff filed an appeal or final appeal, but all of which were dismissed.

On November 16, 2016, the Defendant completed the procedure for the registration of ownership transfer regarding the instant real estate.

E. Of the instant real estate between the Plaintiff and the Defendant, the lease deposit for the lease contract for the fourth floor (hereinafter “instant lease contract”) (hereinafter “instant lease contract”) between the Plaintiff and the Defendant is 65 million won.