1. The Defendant’s KRW 40,000,000 and its related amount are 5% per annum from December 8, 2019 to March 14, 2020 to the Plaintiff.

1. Indication of claim;

A. The plaintiff as the party is the lessee of Seo-gu Incheon Metropolitan City apartment D (hereinafter referred to as "the apartment of this case") and the defendant is the owner of the apartment of this case and the lessor.

[See Evidence No. 1, and Evidence No. 2]

(1) On January 14, 2017, the Plaintiff entered into a lease agreement with Nonparty E, who was the owner at the time, with the lease deposit amount of KRW 40,00,00, and two-year contract period for the instant apartment, and received delivery of the instant apartment. On January 14, 2017, the Plaintiff completed the move-in report on the instant apartment on the date of the contract and received the fixed date. The Defendant purchased the instant apartment from Nonparty E on April 26, 2017. 2) The lease agreement on the instant apartment on the termination of the contract was implicitly renewed on or after January 14, 2019, and the Plaintiff notified the Defendant of the termination of the lease agreement on or after May 28, 2019, and requested the Defendant to return the lease deposit by November 20, 2019, and the Defendant also expressed that the lease deposit was the same as the Plaintiff’s lease deposit.

However, in contrast to the attitude of the defendant, the defendant requested that the apartment of this case be remodeled first, and the new contractor should be paid 60,000,000 won with no price higher than the market price even after the new contractor had been appointed.

Ultimately, the defendant does not refund the lease deposit even after November 22, 2019 that the plaintiff finally requested the return of the deposit.

3. As set forth in the Defendant’s obligation to return the deposit, the lease contract between the Plaintiff and the Defendant was lawfully terminated, and the Defendant’s deposit amounting to KRW 40,00,000 until now.