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

SUPPLEMENTAL AFFIDAVIT OF JIM EICKHOFF IN SUPPORT OF THE DEBTORS MOTION FOR AN ORDER AUTHORIZING DEBTORS TO REJECT CERTAIN EXECUTORY CONTRACTS AND UNEXPIRED LEASES STATE OF MICHIGAN COUNTY OF OAKLAND ) ) ss: )

I, Jim Eickhoff, being duly sworn, state the following under penalty of perjury. 1. I am a Vice President of Engineering for Plastic Products at Collins &

Aikman Products Co., 250 Stephenson Highway, Troy, Michigan 48083.

The Debtors in the proposed 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. 05-55991; 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. 05-55964; 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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2.

I am aware that on November 23, 2005, the above-captioned debtors

(collectively, the Debtors) filed a Motion for Entry of an Order Authorizing Debtors to Reject Certain Executory Contracts and Unexpired Leases (the Motion). 3. On December 7, 2005, the Debtors filed with the Court the Affidavit of

Bill Hoisington in Support of the Motion [Docket No. 1870] and the Affidavit of Jim Eickhoff in Support of the Motion [Docket No. 1871]. 4. I submit this Supplemental Affidavit to provide additional information

regarding the decision-making process through which the Debtors determined that (a) the professional services agreement with PAC-EDGE North America (PAC-EDGE), LLC dated July 1, 2003, (b) the management services agreement with Project Advisors HK Limited (HK Advisors) dated July 1, 2003 and (c) the memorandum of understanding between Collins & Aikman Products Company and PAC-EDGE North America, LLC dated June 20, 2003 (collectively, the PAC-EDGE and HK Contracts) listed on Exhibit B to the Motion should be rejected. 5. Prior to filing the Motion, Bill Hoisington and I examined the terms of the

PAC-EDGE and HK Contracts to determine the benefits and burdens such contracts provide to the Debtors. Benefits Provided by PAC-EDGE and HK Contracts 6. In reviewing and evaluating the PAC-EDGE and HK Contracts, Bill

Hoisington and I began by identifying the benefits the Debtors receive from such contracts. 7. Under the PAC-EDGE and HK Contracts, the Debtors are to receive

personnel and management services to assist the Debtors with a major portion of the engineering and related services on certain vehicle launch programs in which the Debtors are involved.

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8.

Furthermore, under the PAC-EDGE and HK Contracts both PAC-EDGE

and HK Advisors, not the Debtors, are responsible for all compensation, benefits, taxes, unemployment and workers compensation insurance and all other amounts payable with respect to the individuals that perform the services provided pursuant to the PAC-EDGE and HK Contracs. 9. Additionally, under the PAC-EDGE and HK Contracts, any inventions

that an employee of PAC-EDGE or HK Advisors may have conceived or made during the course of providing services to the Debtors pursuant to the PAC-EDGE and HK Contracts is the property of the Debtors. Burdens Imposed by the PAC-EDGE and HK Contracts 10. After identifying the benefits the Debtors receive from the PAC-EDGE

and HK Contracts, Bill Hoisington and I evaluated the burdens imposed on the Debtors by the PAC-EDGE and HK Contracts. 11. Under the PAC-EDGE and HK Contracts, among other things: (a) the

Debtors are required to pay substantial fees based on the number of hours each PAC-EDGE employee works at a rate of approximately $45 per hour (with a 30% premium when a PACEDGE employee works more than 40 hours in a week) (the Hourly Rates); and (b) the Debtors are also required to pay an additional sum to PAC-EDGE based on an estimate of the number of vehicles that will be sold pursuant to each vehicle launch program. 12. Additionally, under the management services agreement, the Debtors are

required to pay an additional amount of approximately 40% of the total amount paid for the Hourly Rates.

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Replacement of PAC-EDGE and HK Advisors Personnel 13. After evaluating the PAC-EDGE and HK Contracts, Bill Hoisington and I

considered the terms upon which the Debtors could retain an alternative service provider to supply services that are substantially similar to the services that PAC-EDGE and HK Advisors currently provide to the Debtors. 14. Engaging an alternative service provider to replace PAC-EDGE and HK

Advisors would be highly beneficial and less cumbersome to the Debtors compared with continuing to retain the services of the PAC-EDGE and HK Advisors. Under an agreement with certain other service providers, the Debtors would (a) pay considerably lower hourly rates; (b) receive substantially greater management services than have been provided by HK Advisors; (c) receive at least the same, if not better, personnel and management services than have been provided by PAC-EDGE and HK Advisors; and (d) be able to hire without penalty any employee who performed services for the Debtors. Determination to Reject the PAC-EDGE and HK Contracts 15. After careful review of the benefits and burdens of the PAC-EDGE and

HK Contracts, Bill Hoisington and I determined that the burdens of the PAC-EDGE and HK Contracts far exceed the benefits to the Debtors and their estates of such contracts for the reasons, among others, set forth below. 16. Specifically, the Debtors have not received any managements services

from HK Advisors, even though such services are to be provided to the Debtors under the PACEDGE and HK Contracts. 17. Moreover, the total costs of the PAC-EDGE and HK Contracts are a

significant burden on the Debtors estates particularly since the current above-market Hourly

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Rates charged by PAC-EDGE (and the corresponding management fee charged by HK Advisors) will increase by 5% in the forthcoming year. 18. Due to these substantial burdens and excessive costs, the Debtors have

determined it necessary to minimize the personnel supplied under the PAC-EDGE and HK Contracts. Within the past several months the Debtors have reduced the number of individuals from PAC-EDGE and HK Advisors working on the vehicle launch programs from twenty to three. 19. Finally, even though PAC-EDGE asserts in its objection to the Motion that

it, and not the Debtors, has claim to certain intellectual property produced in connection with the Ford Fusion vehicle program, this has not been conclusively established. Furthermore, Ford Motor Company is currently pursuing a patent on this intellectual property and has indicated it is comfortable with, and has no objection to, the Debtors rejecting the PAC-EDGE and HK Contracts. 20. After rejection of the PAC-EDGE and HK Contracts, the Debtors will be

able to expand their current relationship with a provider of personnel or enter into an agreement to supply the services currently undertaken by the PAC-EDGE and HK Advisors personnel at lower rates and upon less burdensome conditions. 21. Additionally, the remaining responsibilities that the PAC-EDGE and

HK Advisors personnel perform pursuant to the PAC-EDGE and HK Contracts are no longer necessary since the Ford Fusion program has already launched. In fact, the Debtors have informed the only three remaining PAC-EDGE employees who provide services to the Debtors that the Debtors no longer need their services and will terminate them before the hearing on January 5, 2006.

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In light of and considering all these factors, the Debtors have decided to

reject the PAC-EDGE and HK Contracts. Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true and correct.

/s/ Jim Eickhoff Jim Eickhoff Collins & Aikman Products Co. 250 Stephenson Highway Troy, Michigan 48083 Subscribed and sworn to before me this 16th day of December, 2005. /s/ Pamela J. Lourim Pamela J. Lourim Notary Public, Oakland County, MI My Commission Expires: February 11, 2006

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CERTIFICATE OF SERVICE I, Marc Carmel, an attorney, certify that on the 16th day of December, 2005, I caused to be served, by e-mail, facsimile and overnight delivery, in the manner and to the parties set forth on the attached service lists, a true and correct copy of the foregoing Supplemental Affidavit of Jim Eickhoff in Support of the Debtors Motion for an Order Authorizing Debtors to Reject Certain Executory Contracts and Unexpired Leases.

Dated: December 16, 2005 /s/ Marc J. Carmel Marc J. Carmel

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