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

A. On April 20, 2012, Korea Refrigerants Korea Co., Ltd. (hereinafter “Korea Refrigerants”) reported the value-added tax of KRW 5,194,692,250 for the first time in 2012 to the head of Echeon Tax Office (hereinafter “Defendant”) affiliated with the Defendant, but did not pay the value-added tax. The Defendant, on February 28, 2013, notified the payment deadline of KRW 4,90,000,000 of value-added tax amount.

B. On April 9, 2013, the Plaintiff completed the registration of establishment of a mortgage on the real estate stated in the attached list 14 through 17, owned by Korea Refrigerator, based on the relevant date contract.

C. When applying for deferment of collection to the Defendant, the Korea Refrigerants offered the real estate listed in the attached list 14 through 17 as security. On May 31, 2013, the Defendant completed the registration of creation of a mortgage on the basis of a contract for the provision of security for tax payment on March 27, 2013 (the maximum debt amount 2,528,000,000).

(hereinafter “instant security for tax payment”). D.

On August 22, 2013, the Plaintiff was issued a decision to commence a voluntary auction (hereinafter “instant auction”) with respect to the real estate listed in the attached list A with the Suwon District Court W.

E. At the instant auction, the distribution schedule was prepared on the date of open distribution on August 27, 2014, as follows, and the Plaintiff did not receive any distribution from the proceeds of sale of the real estate stated in the attached Table 14 through 17.

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