A. The Co., Ltd. (hereinafter “Korean Co., Ltd.”) is a company that engages in shipbuilding and repair business of vessels. The Plaintiff and the Defendants recognize the Korean Co., Ltd. as an enterprise showing signs of insolvency on January 29, 2009 in accordance with the Corporate Restructuring Promotion Act and are creditor financial institutions, members of the creditor financial institutions, which have resolved to commence the joint management proceeding of creditor financial institutions.

B. The Plaintiff established the right to collateral security (1) on January 29, 2008, with respect to the land for factory 198,635.4 square meters in Taenam-gun, Youngnam-gun, Taenam-gun, Taenam-gun, Seoul-do, which was owned by Taedong Heavy Industries Co., Ltd. (hereinafter “Than Heavy Industries”), the Plaintiff set the first priority right to collateral security (1) on January 29, 2008, using the debtor as the Taedong Heavy Industries, the amount of maximum debt as KRW 9,100,000,000, and the debtor as the Taedong Heavy Heavy Industries. < Amended by Act No. 843, Jan. 29

(2) On August 19, 2008, the Plaintiff: (a) established the first-class collateral security as the receipt of No. 26565 on August 19, 2008 with respect to the 6 buildings on the ground owned by the Tae Heavy Industries; (b) the debtor as the Tae Heavy Industries; and (c) established the first-class collateral security as to the above land and 6 buildings on the same day (hereinafter collectively collectively referred to as “in-house two factories”) with the Busan District Court’s Youngdong Branch Office as the receipt of No. 26565 on August 19, 2008, with the debtor as the Tae Heavy Heavy Industries; and (d) set the second-class collateral security as to the above land and 3,900,000,000,000 and the debtor as the Tae Heavy Heavy Industries. < Amended by Act No. 26566, Aug. 19, 2008>

(3) In order to secure all debts owed to the Plaintiff in the present and future with respect to the transaction of provisional settlement of gift, the Plaintiff set up a third-class collateral security (hereinafter “third-class collateral security”) as the receipt of No. 30972, Oct. 22, 2008, with respect to the two factories within the Republic of Korea as the maximum debt amount of the Plaintiff, and as the obligor, the Gwangju District Court’s Young-gu District Court’s registration office (hereinafter “instant collateral security”) established on Oct. 22, 2008.

(c) the proceedings of the co-management of the vessel;