1. With respect to all financial transactions made through the account in Appendix 1, the Plaintiff (Counterclaim Defendant).

1. Basic facts

A. The parties’ status 1) The Plaintiff’s new financial investment company (hereinafter “Plaintiff’s new financial investment”).

(1) The Financial Investment Services and Capital Markets Act (hereinafter “Capital Markets Act”) provides for the purpose of investment trading business, investment brokerage business, etc.

(2) The Defendant is the deceased D(Death on July 20, 2012). The Plaintiff is a financial investment business entity under the Financial Investment Services and Capital Markets Act and is an employee of the Plaintiff’s new financial investment branch under the Financial Investment Services and Capital Markets Act.

3) From April 2010, Plaintiff A was designated as a manager of the account in the name of the Defendant and the network (hereinafter “Defendant”). B. The transaction of financial instruments, such as stocks and securities, was conducted from around 2010 to around 2015 through the Defendant or D’s account in the name of the Plaintiff’s new financial investment, and as a result, the Defendant incurred loss to the Defendant. [Grounds for recognition] There was no dispute, Party A’s evidence 3, Party B’s evidence Nos. 1, 5, and 10 (including the number, if any, if any; hereinafter the same shall apply).

each entry, the purport of the whole pleading

2. The parties' assertion

A. Defendant’s assertion 1) The Plaintiffs, through the forgery of signature, etc., forged the Defendant’s signature, thereby making a 12,548 voluntary transaction. The Plaintiffs forged the application for loan, did not prepare the application for loan, or made a voluntary loan (a total amount of loan KRW 33,419,939,687) without any material fact in the application for loan. In particular, the Defendant’s overseas departure period and the attached loan was made during the period of entry into the country, and even during the entry, the said voluntary loan was made. This is prohibited from trading financial investment instruments with the assets deposited from the customer without receiving an offer or order for trading financial investment instruments from the customer or his/her agent. The Plaintiffs violated Article 7 of the Terms and Conditions for Establishment of Trading Accounts (Prohibition of Discretionary Trading) of the Terms and Conditions for Establishment of Securities and Exchange (Article 13 of the Terms and Conditions for Establishment of Trading Accounts).