1. For the Defendant (Counterclaim Plaintiff):

A. The Plaintiff (Counterclaim Defendant) A shall have respect to the share of 1/4 of the real estate listed in the attached Table.

1. Basic facts

A. On April 16, 1991, the Plaintiffs purchased real estate listed in the separate sheet (hereinafter “the instant real estate”) from I in the purchase price of KRW 246,50,000, in collaboration with the deceased H (hereinafter “the deceased”). Of the above purchase price, the Plaintiffs agreed to bear KRW 61,625,00,00 for each of the above purchase price, and the Deceased’s share of KRW 12,250,00 for each of the instant real estate, and the Deceased shall own shares of KRW 1/4,00 for each of the instant real estate.

B. On June 27, 1991, the Deceased completed the registration of ownership transfer with respect to the instant real estate, and on February 14, 2002, the Plaintiffs and J completed the registration of ownership transfer with respect to the portion of 1/2 of the instant real estate on the ground of the promise to sell and purchase as of December 20, 201, Suwon District Court Port Office as the receipt No. 20628 on February 14, 2002.

(hereinafter “The instant provisional registration”). Meanwhile, with respect to the share of 1/4 of the instant provisional registration, Plaintiff A transferred to J the right to share of 1/9 of the instant provisional registration, and Plaintiff B has the right to share of 1/8 of the instant provisional registration.

C. The Deceased died on March 20, 2006, and the Defendants jointly inherited the Deceased as his spouse or children.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 and 2, the purport of the whole pleadings

2. Determination as to the cause of the principal claim

A. On July 1, 1996, the Plaintiffs asserted that the grace period under Article 11 of the Act on the Registration of Real Estate under Actual Titleholder’s Name was expired, and instead acquired ownership of the entire real estate of this case, the Plaintiffs had the obligation to return the amount equivalent to their respective shares in unjust enrichment. The Plaintiffs’ claim for return of unjust enrichment against the Deceased was ten years thereafter.

However, around May 19, 2017 and June 11, 2017, the Defendants, co-inheritors of the deceased, approved the obligations of the Plaintiffs by recognizing that the shares of 1/2 of each of the instant real estate are owned by the Plaintiffs.