1. The Defendant (Counterclaim Plaintiff) is the Incheon District Court regarding each real estate stated in the separate sheet to the Plaintiff (Counterclaim Defendant).

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. In order to guarantee B’s debt owed to the Defendant, the Plaintiff completed the registration of establishment of a neighboring real estate (hereinafter “each real estate of this case”) with respect to each real estate listed in the separate sheet owned by the Plaintiff on December 8, 2014 (hereinafter “instant real estate”) with respect to the registration of establishment of a collateral for the maximum amount of KRW 130,000,000,000, the debtor B, and the Defendant as the debtor B and the Defendant on May 20, 2015, with respect to the registration of establishment of a neighboring real estate as the maximum claim amount of KRW 13716, the maximum claim amount of KRW 65,00,000,000 for the maximum claim amount

(C) Of the real estate of this case, the registration of the establishment of a neighboring mortgage of this case was completed on October 6, 2014 with the maximum debt amount of KRW 130,00,000, the debtor B, and the creditor as the defendant, separate from the registration of the establishment of a neighboring mortgage of this case.

B. The Defendant applied for the voluntary auction of each of the instant real estate to Incheon District Court D upon the registration of creation of a neighboring mortgage, and the registration of the voluntary auction decision was completed on March 22, 2016 by the registration office of the same real estate as the registration office, which received on March 22, 2016.

C. On June 3, 2016, the Plaintiff deposited KRW 195,000,000 with the Defendant as the principal deposit, on the ground that the Plaintiff paid the Defendant a total of KRW 195,000,000 (= KRW 65,000,000) of the maximum debt amount for each of the instant mortgages (i.e., KRW 130,000,000) to the Defendant, but the Defendant was refusing to accept the registration of the establishment of each of the instant environs, on the ground that the Plaintiff’s repayment of KRW 195,00,000 to the Defendant as the principal deposit.

[Ground of recognition] Facts without dispute, Gap evidence 1, Gap evidence 2-1 to 9, the purport of the whole pleadings

2. The parties' assertion

A. The plaintiff asserted as the plaintiff as the plaintiff's surety's surety's debt against the defendant B, which is the maximum debt amount of the registration of creation of each of the neighboring mortgages of this case.