Ex Parte Motions Shortening Notice Period and Scheduling

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IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION,

et al.1 Debtors. ) ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

STATUS REPORT OF CUSTOMER NEGOTIATIONS AND AMENDMENT TO EX PARTE MOTIONS SHORTENING NOTICE PERIOD AND SCHEDULING AN EXPEDITED HEARING ON MOTIONS APPROVING AGREEMENTS WITH TOYOTA MOTOR MANUFACTURING NORTH AMERICA, INC. AND HONDA OF AMERICA MANUFACTURING INC. The above-captioned debtors (collectively, the Debtors) submit this report (the Status Report) to (a) apprise the Court of the status of the Debtors negotiations with their major customers for price relief and other related benefits and (b) amend the Debtors ex parte motions seeking to shorten the notice period and schedule an expedited hearing (collectively, the Ex Parte Motions) on the Debtors motions seeking approval of their agreements with Toyota
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The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

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Motor Manufacturing North America Inc. (Toyota) and Honda of America Manufacturing Inc. (Honda). The Debtors are pleased to report that, in addition to finalizing agreements with Toyota and Honda providing for immediate price relief and other related benefits (collectively, the Toyota and Honda Price Relief Motions), after nearly around-the-clock negotiations over the last several weeks, the Debtors are close to finalizing price relief agreements with most of their remaining major customers. Despite the Debtors best efforts, however, the Debtors do not believe that they will be in a position to file motions to approve agreements with their customers so that all of the motions could be heard on September 30, 2005. Rather, the Debtors anticipate filing motions to approve these agreements or, in the event deals cannot be finalized, motions to reject certain customer contracts, no later than Monday, October 3, 2005. Based on current forecasts, the Debtors have sufficient funds to continue operations while they finalize agreements with their remaining major customers. The Debtors believe it would be very helpful to the Court and all other parties in interest, including the Official Committee of Unsecured Creditors (the Committee) and the Debtors prepetition and postpetition secured lenders (collectively, the Lenders), to consider the Debtors agreements with all of their major customers as a whole. Indeed, neither the Committee nor the Lenders have an objection to moving the hearing on the Toyota and Honda Price Relief Motions to the date requested herein so that all of the customer motions may be heard together. In the event the Debtors finalize agreements with their remaining major

customers on or before October 3, 2005, the Debtors will file motions seeking approval of such

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agreements on an expedited basis to be heard on the same date as the Toyota and Honda Price Relief Motions.2 Accordingly, the Debtors seek the entry of an order, substantially in the form attached hereto as Exhibit A, scheduling an expedited hearing on the Toyota and Honda Price Relief Motions on October 7, 2005, or as soon thereafter as counsel may be heard, and establishing a deadline for objecting or otherwise responding to the Toyota and Honda Price Relief Motions on October 5, 2005 at 4:00 p.m., prevailing Eastern Time.

Notice of this Status Report has been given to the Core Group as required by the First Amended Notice, Case Management and Administrative Procedures [Docket No. 294]. In light of the nature of the relief requested, the Debtors submit that no further notice is required.

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Dated: September 27, 2005

KIRKLAND & ELLIS LLP /s/ Ray C. Schrock Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 300 East Maple Road, Third Floor Birmingham, Michigan 48009 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

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IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION, et al.1 Debtors. ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

ORDER SHORTENING NOTICE PERIOD AND SCHEDULING AN EXPEDITED HEARING ON: DEBTORS MOTIONS FOR ORDER AUTHORIZING ENTRY INTO AGREEMENTS WITH TOYOTA MOTOR MANUFACTURING NORTH AMERICA, INC. AND HONDA OF AMERICA MANUFACTURING INC. PROVIDING FOR IMMEDIATE PRICE RELIEF AND OTHER RELATED BENEFITS Upon the ex parte motions for order shortening notice period and scheduling an expedited hearing (collectively, the Ex Parte Motions) on the Debtors motions for order authorizing the entry into agreements with Toyota Manufacturing North America, Inc. and Honda of America Manufacturing Inc. providing for immediate price relief and other related

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

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benefits (collectively, the Price Relief Motions);2 it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; it appearing that this proceeding is a core proceeding pursuant to 28 U.S.C. 157(b)(2); it appearing that venue of this proceeding and the Ex Parte Motions in this District is proper pursuant to 28 U.S.C. 1408 and 1409; notice of the Ex Parte Motions and the opportunity for a hearing on the Ex Parte Motions was appropriate under the particular circumstances and that no other or further notice need by given; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED 1. 2. The Ex Parte Motions are granted as set forth herein. A hearing on the Price Relief Motions will be conducted before the

Honorable Steven W. Rhodes, on October 7, 2005 at __:__ __.m., prevailing Eastern Time, or as soon thereafter as counsel may be heard in the United States Bankruptcy Courthouse, 211 W. Fort Street, Detroit, Michigan 48226. 3. The objection deadline for the relief requested by the Debtors in the Price

Relief Motions shall be October 5, 2005 at 4:00 p.m., prevailing Eastern Time. 4. The Debtors shall immediately serve a copy of this Order and the Price

Relief Motions upon the Core Group and Affected Parties.3 5. The Debtors are authorized and empowered to take all actions necessary to

implement the relief granted in this Order.

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Capitalized terms used but not otherwise defined in this Order have the meanings assigned in the Price Relief Motions. Capitalized terms used in this paragraph 4 not otherwise defined herein shall have the meanings set forth in the First Amended Notice, Case Management and Administrative Procedures [Docket No. 294].

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6.

The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 7. The Court retains jurisdiction with respect to all matters arising from or

related to the implementation of this Order.

Dated: __________________, 2005 United States Bankruptcy Judge

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