For the Defendant:

A. Based on the Seoul Southern District Court Decision 2015Gahap110509 decided September 15, 2017.

1. Basic facts

A. On September 15, 2017, the Defendant filed a lawsuit against the Plaintiff, including Seoul Southern District Court 2015Gahap110509, the Defendant was sentenced to the judgment of the provisional execution declaration (hereinafter “the judgment of the first instance”) that “the Plaintiff shall pay to the Defendant the amount of KRW 674,278,963 and the interest rate of KRW 15% per annum from July 4, 2017 to the date of full payment” (hereinafter “the judgment of the first instance”).

B. The Plaintiff appealed as Seoul High Court 2017Na2061684 regarding the entire judgment of the first instance court, and the Defendant extended the purport of the claim by filing an incidental appeal.

On January 25, 2019, the appellate court rendered a judgment that “the appellate court shall dismiss the Plaintiff’s appeal, and upon the extension of the Defendant’s purport of the claim, the Plaintiff shall pay to the Defendant the amount of KRW 63,835,616 and the amount calculated by the rate of 15% per annum from November 18, 2017 to the date of full payment” (hereinafter referred to as “appeal judgment”), and the said judgment was finalized on February 13, 2019.

C. On October 10, 2017, the Defendant filed an application for a compulsory auction on real estate D and six buildings owned by the Plaintiff, based on the judgment of the first instance court, the Daegu District Court C, Daegu District Court C, for a compulsory auction on the land and six buildings owned by the Plaintiff. Accordingly, the procedure for compulsory auction on October 12, 2017 was initiated.

(hereinafter “instant auction procedure”). D.

On November 21, 2017, the Plaintiff deposited KRW 39,071,233 (=674,278,963 x 0.15 x 0.15 x 141/365 x 141/365) in total, KRW 713,350,196, calculated by the rate of 15% per annum from July 4, 2017 to November 21, 2017 pursuant to the first instance court’s ruling, which was rendered by the Changwon District Court Jinju Branch Branch of Changwon Branch of 2017 as the principal deposit recipient.

(hereinafter “instant first deposit”). On November 30, 2017, the Defendant reserved an objection to the full amount of the deposit and paid the deposit.

E. On November 27, 2019, the Plaintiff: (a) rendered the Defendant as the principal deposit; (b) the principal of the judgment additionally recognized in the appellate court’s judgment under [13,835,616] as the Jinju Branch Branch Branch of the Changwon District Court in 2019 was KRW 63,835,616; and (c) from November 18, 2017 to November 2019.