1. The Defendants deliver each land indicated in the attached list to the Plaintiff, and the above land area is not less than 25.26m2.

1. As to the cause of claim

A. On January 3, 2003, Nonparty D (1) obtained a construction permit from the head of Ulsan-gu, Ulsan Metropolitan City to the effect that “A 10-story building on the ground of each land listed in the separate sheet (hereinafter referred to as the “instant land”) that “A 10-story building on the ground of reinforced concrete building with a total floor area of 225.26 square meters and a total floor area of 1,812.40 square meters, may be newly constructed on the ground of the instant land,” and suspended the construction of 7-story building on the above ground to the 225.26 square meters of the building area on the ground.

(2) The owner of the instant land was changed several times thereafter. Defendant C acquired the ownership of the instant land on July 18, 2007, and the Defendants transferred the ownership of the said newly constructed building from the said D on November 27, 2007 and changed the name of the owner.

(3) As of February 26, 2007, the instant land was registered for the creation of a collateral security, which was the maximum amount of claims KRW 611 million, North Daegu Agricultural Cooperative Co., Ltd., the mortgagee of the right to collateral security, and Defendant C. However, voluntary auction based on the aforementioned right to collateral security was conducted (Ulsan District Court E), and the Plaintiff acquired the ownership of the instant land in the said voluntary auction procedure, and completed the registration of ownership transfer on October 29, 2010.

(4) On 2010, the Plaintiff filed a lawsuit against the Defendants at the Ulsan District Court to return unjust enrichment to the effect that “The Defendants owned the instant building on the ground of the instant land owned by the Plaintiff without any title, and the Defendants are obligated to pay to the Plaintiff unjust enrichment equivalent to the land rent for the instant land.”

(1) The appellate court of the above case (court 2011Na5882, Oct. 29, 2010) held that “the Defendants jointly and severally pay to the Plaintiff unjust enrichment equivalent to the land rent calculated by the ratio of 27.55 million won per year from October 29, 2010 to the date of the Plaintiff’s loss of ownership or the date of the Defendants’ completion of possession of the building of this case.”