1. The Defendant’s KRW 251,049,680 as well as 5% per annum from July 17, 2015 to October 11, 2017 to the Plaintiff.

1. Indication of claim;

A. On July 10, 2015, the Plaintiff entered into a contract with the Defendant to purchase a specific part of KRW 492 square meters (an amended area of KRW 497,000,000,000,000,000 (hereinafter “instant sales contract”) among the land owned by the Defendant during Seopo-si, Seopo-si, Seopo-si (hereinafter “instant land”), and agreed that the Plaintiff would substitute for the payment of the said purchase price with the money that the Plaintiff paid in advance to the Defendant upon the Defendant’s request. The amount that the Plaintiff paid to the Defendant from April 14, 2015 to July 16, 2015 exceeds KRW 251,049,680 in total.

B. Despite the instant sales contract, the Defendant created a right to collateral security on the instant land in the future of the Korea Saemaul Depository, and the instant land was at the risk of auction due to the Defendant’s failure to repay the secured debt. The Defendant cancelled the right to collateral security and did not perform the obligation to transfer the ownership to the Plaintiff without any burden on the Plaintiff even if the Defendant urged the Plaintiff to repay the debt several times.

C. Accordingly, the Plaintiff is obligated to cancel the instant sales contract by serving the duplicate of the instant complaint. The Defendant is obligated to reinstate the Plaintiff to its original state, to pay the Plaintiff KRW 250 million as unjust enrichment, KRW 1,049,680 as unjust enrichment, and to pay damages for delay from July 17, 2015, which is the day following the last payment date.

2. Article 208 (3) 3 of the Basic Civil Procedure Act (Decision by public notice);