2. Of the statements, the term “total amount” means money and this on February 24, 2009.

A. Of the plaintiffs, the Nos. 1 through 67 and 89 through 91 of the annexed Table 1 (hereinafter “Plaintiff’s commercial workers”) are employed by the defendant and have been in charge of dredging, etc., or are currently in charge of it, commercial workers. Of the plaintiffs, the number Nos. 68 through 88 and 92 through 94 of the annexed Table 1 among the plaintiffs (hereinafter “Plaintiff’s street cleaners”) were employed by the defendant, or they are currently employed as street cleaners.

B. The Plaintiff’s commercial workers have been paid wages according to the collective agreement concluded between the Korean Democratic Union and the Defendant, and the Defendant’s own standards. The Plaintiff’s commercial workers have been paid wages according to the standards for the compilation of a part-time budget for street cleaners, and the Defendant’s own standards. However, the Plaintiff’s commercial workers are paid wages according to the collective agreement concluded on November 2008 between the Sungnam Labor Union and the Defendant.

C. In relation to the scope of ordinary wages that serve as the basis for the payment of overtime work allowances, holiday work allowances, weekly paid holiday allowances, monthly paid holiday work allowances, annual paid holiday work allowances (hereinafter “instant allowances”), the Defendant recognized the basic pay, special work allowances, work encouragement allowances, household support expenses for the Plaintiff’s street cleaners, and the Plaintiff’s ordinary wages as their respective ordinary wages, and based on this, paid the instant allowances to the Plaintiffs.

The Plaintiffs paid the instant allowances and retirement allowances based on the Defendant’s calculation of ordinary wages, even though they were paid as allowances, since they actually maintained the nature of wages, and thus, paid the amount to be included in ordinary wages. This is in violation of the Labor Standards Act, and thus, is new in accordance with the Labor Standards Act.