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

DEBTORS OBJECTION TO RENEWED MOTION OF TOYOTA MOTOR CREDIT CORPORATION FOR ORDER REQUIRING DEBTORS TO ASSUME OR REJECT CERTAIN EQUIPMENT LEASES The above-captioned debtors (collectively, the Debtors) hereby submit this objection (the Objection) to the renewed motion of Toyota Motor Credit Corporation (TMCC) for order requiring the Debtors to assume or reject certain equipment leases (collectively, the Leases) [Docket No. 2048] (the Motion). In support thereof, the Debtors respectfully represent as follows:

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 0555949; 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. 0555958; 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. 0555979; 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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0555927060303000000000007

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Introduction 1. Pursuant to this Courts order entered on November 22, 2005 [Docket No. 1801]

(the Deadline Order), the current deadline for the Debtors to assume or reject the Leases is May 10, 2006 (the Deadline). TMCC now attempts to shorten the Deadline but has offered no compelling reason in the Motion that this Court should do so. Indeed, the Debtors exhaustively have worked with TMCC to resolve its alleged issues, but the Debtors have come to the unfortunate conclusion that the Motion is a misguided attempt by TMCC to use the Debtors bankruptcy filing to receive more than its bargained-for rights under the Leases. Accordingly, for the reasons that are set forth below, the Debtors respectfully submit that the Court should deny the Motion and extend the Deadline until the date a plan of reorganization is confirmed in these cases.2 2. The bases for the relief asserted by TMCC in the Motion are routine concerns for

contract counterparties to a chapter 11 debtor and are not sufficient to compel this Court to grant the extraordinary relief requested. In general, TMCCs stated bases for relief are (a) the Debtors alleged failure to remit postpetition payments pursuant to the Stipulated Order Providing for Adequate Protection Payments to Toyota Motor Credit Corporation, entered on August 11, 2005 [Docket No. 0917] (the Adequate Protection Order); (b) the Debtors failure to provide TMCC with a list of the Debtors plants that are to be closed; and (c) the Debtors use of the equipment under the Leases (the Equipment) in excess of the hours set forth in the Leases. 3. These bases, however, are without merit. First, the Debtors are in full compliance

with the Adequate Protection Order. In particular, the Debtors are current on all postpetition

Given that the Objection involves the same issues the Court would consider in a motion to extend the Deadline pursuant to the Deadline Order, the Debtors respectfully request that the Court consider the Debtors request set forth herein for such an extension.

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amounts due under the Leases and continue to maintain full coverage insurance for the Equipment.3 4. Second, on or about January 31, 2006, as requested by TMCC, the Debtors

voluntarily provided a list of the plants that the Debtors have announced would be closed. This list should enable TMCC to confirm whether any of the Equipment is located at such plants and take any action, subject to compliance with the Leases, it believes is necessary to protect its interests in connection with any such Equipment. 5. Third, although the Debtors use of the Equipment may exceed the hours set forth

in the Leases in certain instances, the Leases explicitly contain hourly overtime charges to compensate TMCC for such use. That is, the very harm TMCC complains of and argues as a basis for assumption or rejection is specifically addressed in the Leases as part of the Debtors bargained-for rights. Pursuant to many of the Leases, these overtime charges are to be billed at the end of the respective lease term or upon termination of the respective lease. The Debtors are confident they have sufficient funds to pay any overtime charges upon being billed for such charges in accordance with the Leases. In the unlikely event the Debtors fail to pay any overtime charges under the Leases TMCC has the same protection every other party that performs services for the Debtors has it is entitled to an administrative expense claim for any benefit it provides the estates. 6. In short, TMCC has provided this Court with no justification for the relief it

requests, and the Motion should be denied.

Although at the time of filing the Motion certain postpetition amounts inadvertently may have been outstanding, the Debtors have since paid all required postpetition amounts. Further, the Debtors have instituted centralized procedures to ensure TMCC is paid timely.

3
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Argument I. Applicable Legal Standards 7. Under section 365 of the Bankruptcy Code, 11 U.S.C. 101-1330 (the

Bankruptcy Code), a debtor may assume or reject an executory contract at any time before the confirmation of a plan . . . 11 U.S.C. 365(d)(2). As one court recently has stated: It has been observed that it is the clear policy of the Bankruptcy Code to provide the debtor with the breathing space following the filing of the bankruptcy petition, continuing until the confirmation of a plan, in which to assume or reject an executory contract. In re Enron Corp., 279 B.R. 695, 702 (Bankr. S.D.N.Y. 2002) (citations omitted). The

provisions of the Bankruptcy Code recognize that [i]t is vitally important to all interested parties that the debtor make a prudent assumption or rejection decision. In re Wheeling-Pittsburgh Steel Corp., 54 B.R. 385, 388 (Bankr. W.D. Pa. 1985) (denying motion to compel assumption or rejection because: (1) the debtors cases were enormous and complex; (2) the determination to assume or reject was complicated and would take significant time; (3) any decision must wait determination of whether debtor would be reorganized or liquidated; and (4) the debtor had continued to perform all of its postpetition obligations) (emphasis in original)). 8. A counterparty to an executory contract, however, may request that the court

compel a debtor to assume or reject the contract prior to confirmation. In such an instance, the settled rule is that a debtor has a reasonable time within which to decide. 3 Collier on Bankruptcy 365.04[2][b] (Lawrence P. King rev. 15th ed., 2002); see Matter of McLouth Steel Corp., 20 B.R. 688 (Bankr. E.D. Mich. 1982) (holding that a debtor is entitled to a reasonable time to decide whether to assume or reject an executory contract and to determine the impact and result its election will have on the formulation of a plan); In re Republic Technologies Intern., LLC, 267 B.R. 548, 554 (Bankr. N.D. Ohio 2001) (When a request is made to determine a

4
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specified period of time to assume or reject an executory contract, Courts have routinely indicated that the debtor has a reasonable time within which to determine whether adoption or rejection of the executory contract would be beneficial to an effective reorganization.); In re Whitcomb & Keller Mortgage Co, Inc., 715 F.2d 375, 379 (7th Cir. 1983) (same). 9. What is a reasonable period of time depends upon the facts and circumstances

of the particular case. 3 Collier on Bankruptcy 365.04[2][b]. In determining whether to compel a debtor to assume or reject an executory contract, one court recently considered the following factors: the damage the non-debtor will suffer beyond the compensation available under the Bankruptcy Code; the importance of the contract to the debtors business and reorganization; whether the debtor has had sufficient time to appraise its financial situation and the potential value of its assets in formulating a plan; the complexity of the case; and the number of contracts that the debtor must evaluate.

Enron, 279 B.R. at 702-703 (considering reasonable period of time during which debtor would have to assume or reject certain pipeline transportation agreements) (citations omitted); see also Theatre Holding v. Mauro, 681 F.2d 102, 105-06 (2nd Cir. 1982). 10. However, [a]bove all, the court should interpret reasonable time consistent with

the broad purpose of chapter 11, which is to permit the successful rehabilitation of debtors. In re Dunes Casino Hotel, 63 B.R. 939, 949 (D.N.J. 1986). II. It is Unreasonable to Compel the Debtors to Immediately Assume or Reject the Leases. 11. As set forth below, an analysis of the above-referenced Enron factors as applied to

the circumstances of these cases leads to the conclusion that it is premature and would be

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detrimental to the Debtors, their estates and their creditors to require the Debtors to immediately assume or reject the Leases or at any time in the immediate future. Rather, the Debtors request that the Court, as explicitly provided by section 365(d)(2) of the Bankruptcy Code and pursuant to the Deadline Order, extend the Deadline until the date a plan of reorganization is confirmed in these cases. (a) 12. First Factor: The Damage TMCC Will Suffer Beyond the Compensation Available Under the Bankruptcy Code. In determining what is a reasonable period for the Debtors to be compelled to

assume or reject the Leases, one may consider what damages, if any, TMCC will suffer that will not be paid in the ordinary course or compensated as a prepetition rejection damages claim (if the Leases are rejected) or as an administrative expense claim under section 503 of the Bankruptcy Code. Here, the Debtors currently are using the Equipment in the ordinary course of their business operations. Such use presents little, if any, physical risk to the Equipment going forward as the Debtors will continue to pay postpetition lease payments and remain current under the Leases pending assumption or rejection. 13. Though at the time of filing the Motion certain postpetition amounts may have

been outstanding, the Debtors have since paid all required postpetition amounts. Indeed, the Debtors have instituted centralized procedures to ensure TMCC is paid timely. In addition, pursuant to the Leases, the Debtors continue to maintain full coverage insurance for the Equipment. TMCC, therefore, pursuant to the Adequate Protection Order, is adequately

protected against any damage to or loss of the Equipment. 14. Furthermore, although the Debtors use of the Equipment may exceed the hours

set forth in the Leases, the Leases explicitly contain hourly overtime charges to compensate TMCC for such use. Pursuant to many of the Leases, these overtime charges are to be billed at 6
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the end of the respective lease term or upon termination of the respective lease. The Debtors are making a good faith effort to work with TMCC to reconcile any postpetition overtime charges pursuant to the terms of the Leases. In the event any outstanding postpetition overtime charges exist, the Debtors will pay such amounts when due in accordance with the terms of the respective Leases. 15. Moreover, to the extent that TMCC performs postpetition services under the

Leases that provide benefit to the Debtors estates, it would be entitled to an administrative expense claim under section 503 of the Bankruptcy Code. Given that the Debtors are timely paying millions of dollars in other administrative expenses monthly, TMCC hardly would suffer any damages by being provided an administrative claim. (b) 16. Second Factor: The Importance of the Leases to the Debtors Business and Reorganization. Since their bankruptcy filing, the Debtors have been reviewing and analyzing

their business operations, including reviewing unexpired leases and executory contracts, to determine whether those leases and contracts are beneficial to the Debtors businesses and estates. In particular, the Debtors have been committed to expeditiously reviewing the Leases. The Debtors, however, are party to approximately 165 Leases with TMCC, and, thus, the Debtors review of the Leases is still ongoing. Indeed, the Debtors are currently in the process of reviewing all of their alternatives in an effort to secure the most cost-effective sources of the type of equipment under the Leases, which would benefit the Debtors, their estates and creditors. 17. In addition, the Debtors decision as to whether to assume or reject their leases

and contracts is dependent upon the Debtors future business plans, which (as discussed below) the Debtors are still formulating with the input and assistance from their advisors, the Official Committee of Unsecured Creditors (the Committee) and the Debtors prepetition and 7
K&E 10993291.3

postpetition senior secured lenders (the Lenders) in connection with the plan of reorganization processes. Accordingly, the Debtors have not formed an informed business judgment as to whether to assume or reject the Leases. (c) Third Factor: Whether the Debtor Has Had Sufficient Time to Appraise Their Financial Situation and the Potential Value of Their Assets in Formulating a Plan. Despite the difficulties and complexities inherent with these cases, in the months

18.

since their bankruptcy filing, the Debtors have made and are continuing to make substantial and rapid progress towards effectuating their rehabilitation and developing a consensual plan of reorganization. In particular, as explained to the Court on prior occasions, the Debtors have been pursuing a dual-track process of undergoing an M&A process for the Debtors businesses (in whole or in part) while also developing a stand-alone plan of reorganization. In furtherance of both exit strategies, in the last three months the Debtors have successfully renegotiated their contracts with key customers (thus addressing the Debtors immediate cash flow issues), stabilized vendor relationships, sold their European operations, enhanced the quality of their management team and are presently implementing their cost reduction plans, which include the shedding of certain non-core assets and operations. At the same time, the Debtors also are implementing key M&A processes, which are approaching their final stages, and undertaking planning and analyses that are necessary precursors to presenting a plan of reorganization. Indeed, it is the Debtors expectation to emerge from chapter 11 this year, and a plan of reorganization is progressing with this target in focus. In sum, the Debtors efforts have resulted in tangible benefits for the businesses and demonstrate marked progress toward a successful emergence from chapter 11. 19. Although the Debtors are approaching a pivotal point in their dual-track process,

they are not yet in a position to make a sound business determination as to which contracts and 8
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leases they should reject or assume. Depending on which path the Debtors take to reorganizing these cases, either assumption or rejection of the Leases may be appropriate. But, again, it is simply inappropriate to force the Debtors to make this decision now before the key plan of reorganization decisions have been made. Thus, under the current circumstances of these cases, it would make no economic or practical sense to compel the Debtors to assume or reject the Leases, particularly in a case such as this where the Debtors are complying with the Leases and the Leases provide a remedy for the issue of which TMCC complains overuse of the Equipment. (d) 20. Fourth Factor: The Complexity of the Case. This bankruptcy, which includes 38 administratively consolidated estates, is

clearly a very complex case. The Debtors have approximately 12,000 employees. The Debtors (together with various North American affiliates that did not file for chapter 11) had approximately $2.7 billion in global revenue in 2004; and they maintain dozens of domestic and foreign manufacturing plants. In short, this case is one of the largest cases ever filed in this District and contains extremely complex issues that the Debtors, the Committee, the Lenders and other key constituencies are attempting to resolve on a fast track. All of the estates resources are focused on emergence, and TMCC should not be allowed to distract the Debtors from this goal. Accordingly, this factor clearly weighs in favor of denying the Motion. (e) 21. Fifth Factor: The Number of Contracts that the Debtors Must Evaluate The Debtors are parties to thousands of contracts and leases, most of which are For the reasons

being evaluated in connection with the plan of reorganization processes.

previously stated, the Debtors require sufficient time to fully and adequately evaluate such contracts and leases in these cases, and this factor again weighs heavily in favor of denying the Motion. 9
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Conclusion 22. For all of the foregoing reasons, the Debtors respectfully submit that the Motion

should be denied and the Deadline extended to the date a plan of reorganization is confirmed in these cases.

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WHEREFORE, the Debtors respectfully request that the Court enter an order, substantially in the form attached hereto as Exhibit A, (a) denying the Motion, (b) extending the deadline for the Debtors to assume or reject the Leases to and including the date a plan of reorganization is confirmed in these cases and (c) granting such other and further relief as is just and proper. Dated: March 3, 2006 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) 4111 West Andover Road West - Second Floor Bloomfield Hills, Michigan 48302 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

K&E 10993291.3

EXHIBIT A

K&E 10993291.3

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 DENYING RENEWED MOTION OF TOYOTA MOTOR CREDIT CORPORATION REQUIRING DEBTORS TO ASSUME OR REJECT CERTAIN EQUIPMENT LEASES Upon the renewed motion of Toyota Motor Credit Corporation for order requiring the Debtors to assume or reject certain equipment leases [Docket No. 2048] (the Motion), it is hereby ORDERED 1. 2. The Motion is denied in its entirety. The deadline by which the Debtors must assume or reject the Leases shall be the

date a plan of reorganization is confirmed for these cases.

1 The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 0555949; 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. 0555958; 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. 0555979; 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.

K&E 10993291.3

3.

The Debtors are authorized to take all actions necessary to effectuate the relief

granted pursuant to this Order. 4. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 5. The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order.

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CERTIFICATE OF SERVICE I, Ray Schrock, an attorney, certify that on the 3rd day of March, 2006, I caused to be served, by e-mail, facsimile and by overnight delivery, in the manner and to the parties set forth on the attached service lists, a true and correct copy of the foregoing Debtors Objection to Renewed Motion of Toyota Motor Credit Corporation for Order Requiring Debtors to Assume or Reject Certain Equipment Leases.

Dated: March 3, 2006 /s/ Ray C. Schrock Ray C. Schrock

K&E 10998071.1

Served via Electronic Mail

NAME A Freeman Adrian City Hall Alice B Eaton Brendan G Best Bryan Clay Champaign County Collector Chris Kocinski City Of Eunice City Of Evart City Of Kitchener Finance Dept City Of Lowell City Of Marshall City Of Muskegon City Of Port Huron City Of Rialto City Of Rochester Hills City Of Salisbury City Of Westland City Of Woonsocket Ri City Treasurer DaimlerChrysler DaimlerChrysler Daniella Saltz Danielle Kemp David H Freedman David Heller David Youngman DuPont Earle I Erman Erin M Casey Frank Gorman Gail Perry Ge Capital GE Polymerland George E Schulman Hal Novikoff Heather Sullivan James A Plemmons Jan Steinle Jim Clough Joe LaFleur Joe Saad John A Harris John Green John J Dawson John S Sawyer Josef Athanas Joseph Delehant Esq Joseph M Fischer Esq K Crumbo K Schultz Kim Stagg Kimberly Davis Rodriguez Leigh Walzer Levine Fricke Inc M Crosby Macomb Intermediate School Marc J Carmel Mark Fischer Michael R Paslay Michael Stamer Michigan Department Of Mike O'Rourke Mike Paslay

NOTICE NAME John Fabor

Barb Neal The Mator at City Hall Roger Elkins City Manager Pauline Houston Lowell Regional Wastewater Maurice S Evans City Manager Bob Robles Treasurer's Office City Treasurer Kurt A Dawson City Assesor Treasurer Business License Div Pretreatment Division Tracy Horvarter

Bruce Tobiansky

Val Venable

Email afreeman@akingump.com cityofadrian@iw.net aeaton@stblaw.com bbest@dykema.com bryan_clay@ham.honda.com bneal@co.champaign.il.us christopher.j.kocinski@bofasecurities.com Eunicela@hotmail.com evartmanager@sbcglobal.net finance@city.kitchener.on.ca MYoung@ci.lowell.ma.us Mevans@cityofmarshall.com roberto.robles@postman.org cphdp@porthuron.org treasurer@rialtoca.gov treasury@rochesterhills.org finwebreq@salisburync.gov finance@ci.westland.mi.us webmaster@woonsocketri.org THovarter@cityofmarshall.com kpm3@daimlerchrysler.com krk4@daimlerchrysler.com dsaltz@ford.com danielle.kemp@lw.com dfreedman@ermanteicher.com david.heller@lw.com David.Youngman@ColAik.com bruce.d.tobiansky@usa.dupont.com eerman@ermanteicher.com ecasey@stblaw.com fgorman@honigman.com perry.gail@pbgc.com rail.sales@ge.com valerie.venable@ge.com ges@dgdk.com HSNovikoff@wlrk.com hsullivan@unumprovident.com jplemmons@dickinson-wright.com jan_steinle@mieb.uscourts.gov jrc8@daimlerchrysler.com joe_lafleur@ham.honda.com js284477@bloomberg.net jharris@quarles.com greenj@millercanfield.com jdawson@quarles.com jss@sawyerglancy.com josef.athanas@lw.com joseph.delehant@sylvania.com jfischer@carsonfischer.com kcrumbo@kraftscpas.com kschultz@tmmna.com kim.stagg@nmm.nissan-usa.com krodriguez@gosrr.com lwalzer@angelogordon.com veronica.fennie@lfr.com mcrosby@akingump.com webmaster@misd.net mcarmel@kirkland.com mark.w.fischer@gm.com mpaslay@wallerlaw.com mstamer@akingump.com treasReg@michigan.gov Michael.Orourke@colaik.com mike.paslay@wallerlaw.com

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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Served via Electronic Mail

NAME Ministry Of Finance Corp Tax Branch Missouri Dept Of Revenue Municipalite Du Village De Nick Shah Nina Rosete Paul Hoffman Pension Benefit Guaranty Corporation Pension Benefit Guaranty Corporation Peter V Pantaleo Phh Canada Inc Philip Dublin Phoenix Contracting Company R Aurand R J Sidman Ralph E McDowell Ray C Schrock Rick Feinstein Ricoh Canada Inc Robert J Diehl Jr Robert Weiss Ronald A Leggett Ronald R Rose Sarah Eagle Sean P Corcoran Sheryl Toby Stark County Treasurer State Of Michigan

NOTICE NAME 15663507 Lacolle

Sara Eagle & Gail Perry Sara Eagle & Gail Perry

William Kinley President

Collector Of Revenue

State Of Michigan State Of Michigan Stephen E Spence Stephen S LaPlante T Pryce Tax Administrator The Corporation Of The Town Thomas Radom Treasurer Of State Tricia Sherick Tyco Capital Inc United Rentals Of Canada Inc Ville De Farnham Voridian Canada Company William C Andrews William G Diehl William J Byrne

Gary D Feigler Treasurer Michigan Dept Of Environmental Quality Environmental Assistance Div Michigan Dept Of Treasury Collection Div Office of Financial Mgmt Cashiers Office Michigan Unemployment Insurance Agency US Trustee

Email info@electionsquebec.qc.ca mied@dor.mo.gov maire@st-zotique.com Nick.Shah@cit.com nina.m.rosete@bofasecurities.com phoffman@bofasecurities.com eagle.sara@pbgc.gov efile@pbgc.gov ppantaleo@stblaw.com phhmail@phhpc.com pdublin@akingump.com WDKinley@aol.com raurand@e-bbk.com rjsidman@vssp.com rmcdowell@bodmanllp.com rschrock@kirkland.com rick.feinstein@ubs.com legal@ricoh.ca rdiehl@bodmanllp.com rweiss@honigman.com leggettr@stlouiscity.com rrose@dykema.com eagle.sarah@pbgc.com sean.p.corcoran@delphi.com stoby@dykema.com sjbolek@co.stark.oh.us deq-ead-env-assist@michigan.gov

Jim Cambio Of Ingersoll Joseph T. Deters

Service de la Tresorerie

treasReg@michigan.gov shuttkimberlyj@michigan.gov steve.e.spence@usdoj.gov laplante@millercanfield.com tpryce@ford.com jcambio@tax.ri.gov elantz@town.ingersoll.on.ca radom@butzel.com treasurer@tos.state.oh.us tsherick@honigman.com Frank.Chaffiotte@cit.com e-rental@ur.com msaintdenis@ville.farnham.qc.ca blanderson@eastman.com kandrews@e-bbk.com wdiehl@e-bbk.com bbyrne@e-bbk.com

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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(no valid e-mail) NAME Acord Inc American General Finance Bayer Material Sciences BNY Midwest Trust Company BNY Midwest Trust Company Brown Corporation City Of Albemarle City Of Battle Creek City Of Longview City Of Sterling Heights City Of Stockton Colbond Inc Dayton Bag & Burlap Co Dow Chemical Co Enerflex Solutions LLC Exxon Chemicals Health Alliance Medical Plans Inc Intertex World Resources Trintex Corp Kentucky Revenue Cabinet Lake Erie Products Meridian Magnesium Office of Finance of Los Angeles Orlando Corporation Pension Benefit Guaranty Corporation Pine River Plastics Inc Progressive Moulded Products Revenue Canada Riverfront Plastic Products Inc Select Industries Corp South Carolina Dept Of Revenue Southco Standard Federal Bank State Of Michigan Teknor Financial Corporation TG North America Town Of Lincoln Finance Office Unique Fabricating Inc Valiant Tool & Mold Inc Vari Form Inc Vericorr Packaging fka CorrFlex Packaging NOTICE NAME John Livingston Linda Vesci Mary Callahan Roxane Ellwalleger Mark Ferderber Utilities Department Income Tax Division Water Utilities James P Bulhinger City Treasurer Economic Development Don Brown Jeff Rutter David Brasseur Todd McCallum Law Dept Ronald Stallworth Bill Weeks Lilia Roman Bankruptcy Auditor Sara Eagle & Gail Perry Barb Krzywiecki Dan Thiffault George Tabry Christine Brown Sales & Use Tax Division Lorraine Zinar Holly Matthews Linda King Bruce B Galletly Raymond Soucie Tom Tekieke General Fax Terry Nardone Adriana Avila FAX 248-852-6074 217-356-5469 412-777-4736 312-827-8542 312-827-8542 616-527-3385 704-984-9445 269-966-3629 903-237-1004 586-276-4077 209-937-5099 828-665-5005 937-258-0029 989-638-9852 248-430-0134 281-588-4606 313-664-8479 770-258-3901 502-564-3875 630-595-0336 517-663-2714 213-368-7076 905-677-1851 202-326-4112 810-329-9388 905-760-3371 902-432-6287 734-281-4483 937-233-7640 803-898-5147 610-361-6082 248-816-4376 517-241-8077 401-725-5160 248-280-2110 401-333-3648 248-853-8422 519-944-7748 586-755-8988 586-939-4216

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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NAME Advanced Composites Inc Akin Gump Strauss Hauer & Feld LLP Assoc Receivables Funding Inc Basell USA Inc Basf Corporation Butzel Long PC Canada Customs & Rev Agency Canada Customs & Rev Agency Charter Township Of Plymouth City Of Barberton City Of Barberton City Of Canton City Of Dover City Of Dover City Of Evart Recreation Dept City Of Fullerton City Of Havre De Grace City Of Los Angeles City Of Phoenix City Of Roxboro City Of St Joseph City Of Williamston City Treasurer Collector Of Revenue Collins & Aikman Corp DuPont Dykema Gossett PLLC ER Wagner Manufacturing Fisher Automotive Systems Fisher America Inc Freudenberg Nok Inc Ga Dept Of Revenue Gaston County Ge Capital Ge Capital Ge Capital Ge Capital Comm Serv Astro Dye Highwoods Forsyth Lp Highwoods Forsyth Lp Hnk Michigan Properties Indiana Department Of Revenue Indiana Dept Of Revenue Industrial Development Board Industrial Leasing Company Industrial Truck Sales & Svc Inmet Division of Multimatic Internal Revenue Service

NOTICE NAME Rob Morgan Michael S Stamer Philip C Dublin Jim Frick Charlie Burrill Thomas B Radom Attn Receiver General International Tax Service Ohio Income Tax City Building Canton Income Tax Dept Wastewater Labroratory

Mary Ellen Hinckle Dept Of Building And Safety City Attorneys Office Tax Department Water Department Port Huron Police Department Barbara J Walker Stacy Fox Susan F Herr Ronald Rose & Brendan Best Gary Torke William Stiefel

ADDRESS1 1062 S 4th Ave 590 Madison Ave PO Box 16253 7925 Kingsland Dr 1609 Biddle Ave 100 Bloomfield Hills Pkwy Ste 100 1 5 Notre Ave 2204 Walkley Rd PO Box 8040 576 West Pk Ave 576 West Pk Dr PO Box 9951 484 Middle Rd PO Box 818 200 South Main St 303 W Commonwealth Ave 711 Pennington Ave 201 N Figueroa St No 786 200 W Washington St 13th Fl PO Box 128 700 BRd St 161 E Grand River 100 Mcmorran 201 N Second St 250 Stephenson Hwy DuPont Legal D 7156 400 Renaissance Center 4611 North 32nd St 1084 Doris Rd 47690 E Anchor Ct PO Box 105499 PO Box 890691 PO Box 740434 PO Box 640387 PO Box 642444 PO Box 60500 Attn Lease Administration Attn Lease Administration 7255 Crossleigh Court Ste 108 100 N Senate Ave PO Box 7218 PO Box 4660 PO Box 1803 PO Box 1807 35 West Milmot St Box 330500 Stop 15

ADDRESS2

File 54563

1007 N Market St

CITY Sidney New York Greenville Raleigh Wyandotte Bloomfield Hills Sudbury Ottawa Plymouth Barberton Barberton Canton Dover Dover Evart Fullerton Havre De Grace Los Angeles Phoenix Roxboro St Joseph Williamston Port Huron St Charles Troy Wilmington Detroit Milwaukee Auburn Hills Plymouth Atlanta Charlotte Atlanta Pittsburgh Pittsburgh Charlotte

STATE OH NY SC NC MI MI ON ON MI OH OH OH NH NH MI CA MD CA AZ NC MI MI MI MO MI DE MI WI MI MI GA NC GA PA PA NC TN NC OH IN IN AL MI NC ON MI

ZIP 453658977 10022 29606 27613-4203 48192 48304 P3A 5C2 K1A 1B1 48170-4394 44203 44203-2584 44711-9951 03820 03820-0818 49631 92632 21078 90012 85003 27573 49085-1355 48895 48060 63301 48083 19898 48243 53209-6023 48326-2613 48170 30348-5499 28289-0691 30374 15264-0387 15264 28260 37203-5223 27604 43617 46204-2253 46207-7218 36103-4660 49501 27702-1807 L4B 1L7 48232

COUNTRY

Canada Canada

Director's Office for Taxpayer Services Division

co Highwoods Properties Llc co Highwoods Properties Llc co Rudolph libbe Properties

of the City of Montgomery

SBSE Insolvency Unit

2120 West End Ave Ste 100 Nashville 3100 Smoketree Ct Ste 600 Raleigh Toledo Indianapolis Indianapolis Montgomery Grand Rapids Durham Richmond Hill Detroit

Canada

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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NAME Invista ISP Elastomer Janesville Products Keith Milligan Kilpatrick & Associates PC Latham & Watkins LLP Lear Corp Manpower Meridian Park Ministre Du Revenu Du Quebec Municipality Of Port Hope North Loop Partners Ltd PolyOne Corp Prestige Property Tax Special Princeton Properties Qrs 14 Paying Agent Qrs 14 Paying Agent Inc Railroad Drive Lp Receiver General For Canada Receiver General for Canada Receiver General For Canada Receiver General for Canada Revenue Canada Securities and Exchange Commission Simpson Thacher & Bartlett LLP State Of Alabama State Of Michigan State Of Michigan State Of Michigan State Of Michigan State of Michigan State of Michigan Central Functions Unit Stephen E Spence Summit Property Management Inc Tate Boulevard I Llc Tax Collector Tcs Realty Ltd The Town Of Pageland Tom Heck Truck Service Town Of Farmington Town Of Farmville Town Of Gananoque Town Of Old Fort Town Of Pageland Town Of Troy Tr Associates Treasurer City Of Detroit Unifi Inc

NOTICE NAME Tim Gorman Laura Kelly Leonora K Baughman David Heller Josef Athanas & Danielle Kemp C Garland Waller

co Beer Wells Real Estate Woody Ban

ADDRESS1 601 S LA Salle St Ste 310 PO Box 4346 2700 Patterson Ave 3745 C Us Hwy 80 W 903 N Opdyke Rd Ste C Sears Tower Ste 5800 21557 Telegraph Rd 30800 Northwestern Hwy 2707 Meridian Dr 3800 Marly PO Box 117 PO Box 3449 33587 Walker Rd 1025 King St East 678 Princeton Blvd Church St Station 50 Rockefeller Lobby 2 100 Vesper Executive Pk

ADDRESS2

233 S Wacker Dr

PO Box 6529

CITY Chicago Houston Grand Rapids Phenix Auburn Hills Chicago Southfield Farmington Hills Greenville Ste Foy Port Hope Longview Avon Lake Cambridge Lowell New York New York Tyngsboro Ottawa Dorval Belleville Dorval Ottawa Chicago New York Montgomery Lansing Lansing Detroit Lansing Lansing Lansing Detroit Southfield Hickory Fresno Trenton Pageland Urbana Farmington Farmville Gananoque Old Fort Pageland Troy Troy Detroit Greensboro

STATE IL TX MI AL MI IL MI MI NC QC ON TX OH ON MA NY NY MA ON QC ON QC ON IL NY AL MI MI MI MI MI MI MI MI NC CA ON SC IL NH NC ON NC SC NC MI MI NC

ZIP 60605-1725 77210 49546 36870 48326 60606 48034 48334 27834 G1X 4A5 L1A 3V9 75606 44012 N3H 3P5 01851 10249 10020-1605 01879-2710 K1A 1B1 H4Y 1G7 K8N 2S3 H4Y 1G7 K1A 9Z9 60604 10017-3954 36104 48909 48909 48277-0833 48909 48918-0001 48909-8244 48226 48075 28602 937151192 K8V 5R1 29728 61802 03835 27828-1621 K7G 2T6 28762 29728 27371 48083 48232 27410-6237

COUNTRY

Canada Canada

Canada

Canada Customs & Rev Agency Technology Ctr 875 Heron Rd 700 Leigh Capreol 11 Station St 700 Leigh Capreol Ottawa Technology Centre Midwest Regional Office 175 W Jackson Blvd Ste 90 Peter Pantaleo Erin Casey & Alice Eaton 425 Lexington Ave Department Of Revenue Dept Of Commerce & Nat Res PO Box 30004 Matthew Rick Asst Attorney General PO Box 30754 State Of Michigan Mc Dept 77833 State Secondary Complex 7150 Harris Dr PO Box 30015 430 W Allegan St Jennifer Nelles US Trustee First Plaza County Of Fresno Office of Child Support 211 W Fort St Ste 700 24901 Northwestern Hwy 302 1985 Blvd Se PO Box 1192 21 Albert St 126 North Pearl St 1306 E Triumph Dr 356 Main St 115 West Church St 30 King St East PO Box 520 PO Box 67 315 North Main St 200 E Big Beaver PO Box 33525 7201 W Friendly Ave

875 Heron Rd

Canada Canada Canada Canada Canada

50 N Ripley St

PO Box 30744

PO Box 2228

Canada

PO Box 67

Farmville Downtown Partnership

PO Box 100

Canada

Fsia Inc

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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NAME Uniform Color Co United States Attorney for the Eastern District of Michigan Valeo Inc Vespera Lowell Llc Village Of Holmesville Village Of Rantoul Visteon Climate Control W9 Lws Real Estate Limited Wachtell Lipton Rosen & Katz Wellington Green LLC

NOTICE NAME Randy Lueth Attn Civil Division Jerry Dittrich Blue Point Capital Bpv Lowell LLC

ADDRESS1 12003 Toepher Rd 211 W Fort St Ste 2001 3000 University Dr 10 Livingston Pl 2nd Fl 205 Millersburg Rd 333 S Tanner One Village Center Dr

ADDRESS2

CITY Warren

STATE MI MI MI CT OH IL MI NC NY MI

ZIP 48089-3171 48226 48326-2356 06830 44633 61866 48111 28262-2337 10019 48025

COUNTRY

Detroit Auburn Hills Greenwichn PO Box 113 Holmesville Rantoul Van Buren Ste PO RFQ Office Township Charlotte New York Bingham Farms

co Lincoln Harris Llc Hal Novikoff

10101 Claude Freeman Dr Ste 200 N 51 W 52nd St 31100 Telegraph Rd Ste 200

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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