A. On August 14, 2010, the Defendant drafted a letter stating that the Plaintiff borrowed KRW 100 million from the Plaintiff on December 31, 2010 (hereinafter “instant letter”).

B. On December 27, 2010, the Plaintiff prepared a certificate of borrowing KRW 1.22 million between the Defendant, C, and D (hereinafter “the instant certificate of borrowing”). According to the said certificate of borrowing, the Plaintiff leased KRW 100 million to C, and the agreed interest is determined as KRW 20 million on September 30, 201, and the Defendant and D jointly and severally guaranteed the above obligation of borrowing KRW 1.2 million.

around that time, the Plaintiff completed the registration of creation of a collateral with regard to the claim amounting to KRW 120,000,000 against C as the secured debt, whereby the mortgagee is the Plaintiff and the maximum debt amount as to the building E and its ground buildings owned by Chungcheongnam-gun, Geumsan-gun and its ground.

C. On the other hand, on September 28, 2009, prior to the preparation of the instant letter, the Plaintiff entered into a contract with the FF and H, the representative director of G, and paid KRW 50 million to H via the Defendant, upon entering into the agreement to operate the brine at the construction site of the GJ district in Gwangju-si I and J district. Upon the conclusion of the contract, H, on October 7, 2009, entered into a letter of payment stating that H would compensate the Plaintiff for KRW 100 million. On October 28, 2010, the Plaintiff drafted a letter of performance stating that the said KRW 100 million will be paid by December 30, 2010.

Around March 2, 2013, the Defendant: (a) prepared a letter of agreement that the Defendant would pay KRW 200 million to the Plaintiff as a guarantor with respect to the Defendant’s obligation to the Plaintiff (hereinafter “instant letter of agreement”); and (b) written on March 21, 2013, a letter of agreement that the Defendant would pay KRW 25 million to the Plaintiff as a guarantor (hereinafter “instant letter of interest payment”); and (c) written on March 21, 2013, a letter of agreement that the Plaintiff would pay KRW 25 million to the Plaintiff (hereinafter “instant letter of agreement”).

E. On November 13, 2014, the Plaintiff’s land and building owned by the said C.