2. The costs of lawsuit shall be borne by the Plaintiff.

A. On January 26, 2010, the Defendant extended a loan of KRW 890 million to D with interest rate of KRW 18 million per annum, and damages for delay rate of KRW 18% per annum (hereinafter “first loan”). On the same day, the Defendant completed the registration of creation of a mortgage (hereinafter “instant mortgage”) with respect to apartment units (hereinafter “instant apartment”) owned by Seocho-gu Seoul Metropolitan Government E 121-2303, Seocho-gu, Seoul (hereinafter “instant apartment”) with the obligor D and the maximum debt amount of KRW 1157 million. However, the written agreement of the instant mortgage was in blank as to the scope of the secured obligation, the column for indicating whether the secured collateral is specific collateral, limited collateral security, and comprehensive collateral security is public.

B. In addition, on January 28, 2010, the Defendant extended a loan of KRW 440 million to D with interest rate of KRW 18 million per annum, and damages for delay rate of KRW 18% per annum (hereinafter “second loan”). On the same day, the Defendant completed the registration of the establishment of a neighboring apartment of KRW 809,000,000 for the obligor D and the maximum debt amount of KRW 572,000 with respect to the apartment of KRW 604,000 (hereinafter “overcheon apartment”) owned by D, 300,000,000. Of the written contract establishing the right to collateral security, specific collateral security, limited collateral security, and the indication column of whether the collateral security was secured is vacant.

C. After that, on March 20, 2012, the Plaintiff leased the instant apartment from D with the term of KRW 1.5 billion and the contract period as of March 29, 2014. On March 30, 2012, the Plaintiff completed the resident registration registration of the instant apartment and obtained the fixed date of the said lease agreement.

On the other hand, D’s creditor G applied for a compulsory auction on May 16, 2012 for the instant apartment based on the authentic copy of a promissory note deed, and the said court rendered a decision to commence compulsory auction on May 17, 2012 (hereinafter “instant compulsory auction procedure”), and the Plaintiff, as a lessee, demanded the repayment of KRW 1.5 billion against D on June 13, 2012 during the said compulsory auction procedure, to demand the repayment of KRW 1.5 billion against D, and the Defendant against D to the said court on August 6, 2012.