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Response of Shawmut Corporation To The Collins & Aikman Litigation Trust'S Twenty-Eighth Omnibus Ojbection To Claims (Multidebtor Duplicate Claims)
Response of Shawmut Corporation To The Collins & Aikman Litigation Trust'S Twenty-Eighth Omnibus Ojbection To Claims (Multidebtor Duplicate Claims)
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No. 05-55927 (SWR) (Chapter 11) Jointly Administered Tax ID No. 13-3489233
RESPONSE OF SHAWMUT CORPORATION TO THE COLLINS & AIKMAN LITIGATION TRUSTS TWENTY-EIGHTH OMNIBUS OJBECTION TO CLAIMS (MULTIDEBTOR DUPLICATE CLAIMS)
Shawmut Corporation (Shawmut), a secured and unsecured creditor of the Debtors, hereby responds to The Collins & Aikman Litigation Trusts Twenty-Eighth Omnibus Objection to Claims (Multidebtor Duplicate Claims) (the Trust; the Twenty-Eighth Objection). Shawmut is prepared to acquiesce in the disallowance sought in the Twenty-Eighth Objection, of the unsecured portion of Shawmuts claims nos. 3210 and 3214, provided that its surviving claim, claim no. 3411 properly survives intact with respect to both of its as-filed amounts: (i) secured $426,954.48, and (ii) unsecured $4,169.67. The Trust provides no support, let alone explanation, for its omission of the unsecured portion of Shawmuts claim no. 3411. Perhaps the omission was inadvertent; in any event, there is no basis therefor.
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CONCLUSION For all the foregoing reasons, the Trusts objection to Shawmuts claims in the TwentyEighth Objection should be overruled, Shawmuts claim no. 3411 should be allowed in the secured amount of $426,954.48 and the unsecured amount of $4,169.97, and Shawmut should be accorded all such other and further relief as may be just. Respectfully submitted, SHAWMUT CORPORATION By its attorneys, ERMAN TEICHER MILLER ZUCKER & FREEDMAN, P.C. /s/ Julie Beth Teicher Julie Beth Teicher (P34300) Attorneys for Shawmut Corp. 400 Galleria Officentre, Suite 444 Southfield Michigan 48034 Telephone 248 827 4100 jteicher@ermanteicher.com Dated: May 12, 2008 Of counsel: Peter Nils Baylor (BBO 033920) Nutter, McClennen & Fish, LLP World Trade Center West 155 Seaport Boulevard Boston, MA 02210-2604 (617) 439-2000
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