1. The defendant shall be the plaintiff.

(a) Appendix 1 List

1. The registration of the branch court of Busan District Court with respect to real estate; and

1. The following facts do not conflict between the Parties:

On March 30, 2012, the Plaintiff entered into a mortgage contract with the Defendant, and on the same day, the attached list 1 to the Defendant.

1. On March 30, 2012, the Busan District Court completed the registration of the establishment of a mortgage on real estate and the registration of the establishment of a mortgage on real estate in the amount of KRW 100,000,000,000, the mortgagee, the debtor, and the maximum debt amount.

B. On September 7, 2012, the Plaintiff entered into a mortgage contract with the Defendant, and on the same day, the attached list 1 to the Defendant.

2. On September 7, 2012, the Changwon District Court Kim Jong-hae registry office of the Republic of Korea completed the registration of establishment of a neighboring mortgage (hereinafter “registration of establishment of a neighboring mortgage”) of KRW 100,000,000 on the real estate, along with the registration of establishment of a neighboring mortgage (hereinafter “registration of establishment of a neighboring mortgage”).

2. The parties' assertion

A. The Plaintiff’s assertion ① The Plaintiff is a construction site manager at which the Defendant had supplied stone or managed daily workers, etc. from March 2012 to November 2013 at each construction site indicated in attached Table 2 (hereinafter “instant construction site”) that he/she subcontracted the construction work from the contractor to the contractor.

② The Plaintiff set up the instant collateral security right to secure the payment of damages to the Defendant by negligence in relation to the supply management or the management of daily workers at the construction site of this case.

③ The Plaintiff did not incur any damage to the Defendant by faithfully performing the construction site management duties from March 2012 to November 30, 2013, which had been solely performed at the Defendant’s unilateral demand. As such, the instant collateral security right does not exist and ought to be cancelled due to the lack of the secured obligation.

B. Defendant’s assertion ① The Plaintiff is a sub-subcontract that re-subcontracted part of the shipbuilding work (i.e., piling up a fence with stone, brick, block, etc.) that the Defendant subcontracted to the instant construction site.