A. On February 22, 2007, the Defendant constituted “D consortium” with Nonparty C, etc., and entered into an agreement on cooperation regarding “E development projects” with Yangyang-si. The agreement was established on February 27, 2007, and accordingly, B was established on February 27, 2007. (ii) around 2016, the Defendant had 57% shares in B, and transferred 15% of them to a third party on April 22, 2016.

B. On December 1, 2015, B entered into a sales contract with Non-Party F Co., Ltd. to sell 19,553.4m2 and other structures under construction on the Plaintiff’s land at KRW 48.5 billion (excluding value-added tax) with the payment deadline on September 30, 2016, the Plaintiff notified Non-Party B of KRW 1,124,971,730 of value-added tax at the payment deadline on September 30, 2016, while the Plaintiff reported value-added tax on the transfer of the said real estate and did not pay taxes. By August 18, 2017, the Plaintiff was in arrears with taxes of KRW 1,280,217,820.

C. On June 1, 2016, the Defendant filed an application for a payment order against B for a total of KRW 3,643,744,790 against B. The above payment order was served on B’s domicile on the registry on June 7, 2016 and “H” was served as a member of the general affairs of B, and was treated as the payment order was finalized on June 22, 2016 without filing an objection (hereinafter “instant payment order”).

(2) On July 12, 2016, the Defendant filed an application for a seizure and collection order with B as the executive title of the instant payment order as the debtor, corporation I, and corporation J as the third debtor. On July 18, 2016, the original copy of the decision on the seizure and collection order was served on the third debtor on July 18, 2016.

3) On July 15, 2016, the I Bank Account (a KRW 600 million was deposited in K) under the name of B on July 15, 2016, and the Defendant is KRW 600 million from the I Bank, a third debtor, according to the above collection order on July 20, 2016.