1. The Defendant (Counterclaim Plaintiff) shall deliver to the Plaintiff (Counterclaim Defendant) the real estate indicated in the separate sheet.

2...

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. The Plaintiff is the owner who completed the registration of ownership transfer on the real estate listed in the separate sheet on July 18, 2008 (hereinafter “instant real estate”) based on sale and purchase as of June 28, 2008.

B. On July 5, 2010, Defendant B leased the instant real estate as the lease deposit amount of KRW 16 million and the lease period of KRW 12 months from August 9, 2010, and obtained the fixed date as of July 30, 2010.

In addition, Defendant B and its children filed a move-in report on the instant real estate on July 30, 2010 and thereafter Defendant C were residing together in the instant real estate until now.

C. On April 1, 2016, the Defendants sent to the Plaintiff a written request for the return of lease deposit amounting to KRW 16 million as content certification until June 30, 2016 (the content certification was delivered to the Plaintiff on April 4, 2016). On June 30, 2016, the Defendants sent to the Plaintiff a written statement stating that “written request for the return of lease deposit (the content certification was delivered to the Plaintiff on April 4, 2016),” which read “written request for the return of lease deposit (the secondj)” to the Plaintiff. As the lease contract expired at the expiration of the lease term, the Defendants sent the written statement demanding the return of the deposit.

(The above document was delivered to the Plaintiff on July 4, 2016). 【Evidence 1, 2, and 3, Eul evidence 1-1, Eul evidence 4, 5, and Eul evidence 6-1 and 2

2. Summary of parties' arguments;

A. The Defendants asserting that they are residing in the instant real estate by leasing the instant real estate from Nonparty D, and D is not a legitimate agent of the Plaintiff.

Therefore, since the Defendants possessed the instant real estate without legitimate title, they should deliver the instant real estate to the Plaintiff as the owner.

B. The lease contract concluded with respect to the instant real estate asserted by the Defendants was terminated at the expiration of the term.

Therefore, the Plaintiff, a lessor, should return the lease deposit amount of KRW 60 million to the Defendants.

The plaintiff asserts that D is not a legitimate representative of the plaintiff, but D.