1. The Plaintiff:

A. Defendant B’s share of 1/2 of the real estate indicated in the attached list is the Seoul Western District Court on February 2013.

1. Basic facts

A. The Plaintiff married with Defendant B in 1961 and placed Defendant C (C), Nonparty D (V), and E (V) as his child.

B. On January 30, 2013, Defendant B completed the registration of ownership transfer for the portion of 1/2 portion of the real estate listed in the separate sheet owned by the Plaintiff (hereinafter “instant real estate”), which was based on the donation made from January 30, 2013 to Seoul Western District Court Decision 3632, and the registration of ownership transfer for the remainder of 1/2 portion of the said real estate on February 20, 2013 to the same court under Article 6289 of the same Court’s receipt as to January 30, 2013 (hereinafter “the second registration of ownership”).

C. On October 18, 2013, Defendant B completed the registration of the establishment of the mortgage (hereinafter “registration of the instant mortgage”) of the maximum debt amount of KRW 700 million on the ground of the contract to establish the right to collateral security (hereinafter “right to collateral security”) against Defendant C, under Article 4523 of the Seoul Western District Court’s receipt of the Seoul Western District Court on October 17, 2013.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 4, 6, 13, and 15 (including each number), the purport of the whole pleadings

2. Determination as to the claim for cancellation of the first registration of ownership against Defendant B

A. The gist of the Plaintiff’s assertion is that the Plaintiff signed and sealed directly on the gift agreement, power of attorney, etc. regarding the donation that is the cause of the first registration of ownership.

However, the above gift contract is signed and sealed by Defendant B as if it was an insurance contract, while it is possible to reduce the tax if he/she purchased an insurance policy with weak vision and sense of view to the Plaintiff.

As such, since the first registration of ownership is completed by deception of Defendant B, etc., it is naturally null and void, Defendant B is obligated to cancel the above registration of ownership.

(State) If the above registration of ownership is not void as a matter of course, the Plaintiff is a donation contract which is the cause of the above registration of ownership through the service of the preparatory document dated August 16, 2018.