1. The defendant has caused the plaintiff to return unjust enrichment with respect to each real estate stated in the separate sheet.

1. Indication of claim;

A. A. Around October 1986, the Plaintiff purchased each real estate listed in the separate sheet (hereinafter “each real estate of this case”) with the Defendant and completed the registration of ownership transfer under the name of the Defendant, and entered into a title trust agreement with the purport that the Plaintiff would bear the purchase price of each real estate of this case and hold ownership of each real estate within the country.

(hereinafter “instant title trust agreement”). B.

Pursuant to the above title trust agreement, the Defendant purchased each of the instant real estate from C on October 18, 1986 in KRW 11,856,980 (hereinafter “instant sales contract”), and completed the registration of ownership transfer on October 20, 1986.

C. C, the seller of the instant sales contract, was unaware of the existence of the title trust agreement between the Plaintiff and the Defendant.

The instant case constitutes “when the title truster and the Defendant, the title trustee, entered into a title trust agreement prior to the enforcement of the Real Estate Real Name Act. Accordingly, the Defendant entered into a sales agreement with the owner who was unaware of the fact that the title trust agreement was a party thereto, and the period has elapsed without completing the registration of title transfer of the pertinent real estate within the grace period stipulated in Article 11 of the said Act after completing the registration of title transfer in the name of the trustee pursuant to the said sales agreement.” The Defendant acquired the entire ownership of each of the instant real estate by acquiring the ownership of each of the instant real estate

E. Even if the instant title trust agreement is valid, a duplicate of the instant complaint containing an expression of intent to terminate the instant title trust agreement was served on December 23, 2014, and thus, the instant title trust agreement was lawfully terminated on the same day.

G. Therefore, the defendant shall make unjust enrichment on each of the instant real estate to the plaintiff.