1. The Plaintiff:

A. Defendant B: (a) from March 22, 2019, KRW 189,060,056 and its related thereto:

B. Defendant C shall be KRW 220,674,430.

1. Basic facts

A. 1) The Defendant C purchased land from Pyeongtaek-si on April 22, 1996 (hereinafter “Fri”)

(2) Of G, the sales contract was concluded in the name of “C et al.” with the content of purchasing KRW 4,000,000 among KRW 120,000 in KRW 120,00 in KRW 2.2) Defendant C concluded a sales contract in the name of “C et al.” with the content of purchasing KRW 4,820 in I forest land from KRW 144,60,00 in the same day.

3) Total sum of G forest land 13,223 square meters, and 15,950 square meters of I forest land (hereinafter “instant land”).

On October 28, 1996, the registration of transfer of ownership was completed on the part of the Plaintiff, Defendant B, and C with respect to each one-third share on October 23, 1996. (B) On September 11, 2007, the Plaintiff, Defendant B, and C entered into a sales contract for selling the instant land in KRW 2,206,00,000 (hereinafter “the instant sales contract”).

2) On September 11, 2007, the Plaintiff received down payment of KRW 220,00,000 from the buyers of the instant sales contract, and KRW 1,00,000 from the intermediate payment of KRW 1,00,000 on October 25, 2007. The Plaintiff paid KRW 1,180,000,000 (hereinafter “the instant revenue”). The remainder 1,180,000,000 (hereinafter “the instant revenue”).

Of these, Defendant B and C paid KRW 295,000,000 each of them, and remitted KRW 60,000,000 on December 10, 2007 to Defendant D, respectively, and KRW 120,000,000 on March 15, 2010. 3) The Plaintiff received “temporary rent” from Defendant C, stating that “one million won was paid at the expense of an attorney-at-law out of the borrowed / the above amount.”

4) Meanwhile, around 2008, J and K filed a lawsuit claiming the refund of the purchase price against the Plaintiff, Defendant B, and C (hereinafter “related lawsuit”).

On December 15, 2008, mediation was concluded to pay 1,220,000,000 won to J and K as of January 20, 2009 and damages for delay from May 1, 2008.

The costs of the relevant lawsuit shall be KRW 7,000,000 by Defendant C, and KRW 1,00,000 by Defendant B, respectively.