1. As to the real estate stated in the attached list to the Plaintiff:

A. Ansan District Court's Ansan Branch on June 15, 2010

1. Basic facts

A. As to the real estate listed in the separate sheet owned by the Plaintiff (hereinafter “instant real estate”), the Plaintiff completed the registration of the establishment of a mortgage in the Defendant’s name, the obligor and the maximum debt amount of KRW 100 million, on the ground of the contract to establish a contract, which was received on June 15, 2010, No. 53784, Jun. 15, 2010, which was concluded on June 14, 2010.

(hereinafter referred to as "first priority mortgage"). (b)

The Defendant received a sub-subcontract from D Co., Ltd. with respect to electrical construction, etc. (hereinafter “instant construction”) among the “E construction works” that Nonparty D received from the Korea Land and Housing Corporation.

C. C entered into an agreement on the performance of construction works (hereinafter “instant agreement”) with C on December 5, 2014 with respect to the instant construction works, which was executed by the Defendant as the site manager at the instant construction site on December 5, 2014 (hereinafter “instant construction works”). In preparation for the case where C is liable for damages to the Defendant as the site manager, C performed the said construction works, C notarized and offered a notarized security article equivalent to KRW 150 million in order to ensure the smooth progress of construction works and to build mutual trust, and replaced with a security article (F) established for KRW 10 million, and provided an additional security article for KRW 50 million (hereinafter “instant agreement”).

The Plaintiff completed the registration of creation of a mortgage in the name of the Defendant with the obligor C and the maximum debt amount of KRW 50 million on the ground of a contract concluded on January 5, 2015, which was received as No. 523 from the Suwon District Court, as to the additional security under the instant provision of collateral, on January 5, 2015.

(hereinafter referred to as "second priority mortgage")

E. C filed a lawsuit against the Defendant with Seoul Western District Court 2018Gahap30504 (principal lawsuit) (the Seoul Western District Court) seeking the cancellation of the first and second collateral mortgages, and the Defendant filed a lawsuit against C with the said case as 2018Gahap33596 (Counterclaim).