UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION, et al.

Debtors. ______________________________/ Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) Hon. Steven W. Rhodes

VERIFIED STATEMENT OF JACOB & WEINGARTEN, P.C. PURSUANT TO F.R.BANKR.P. 2019 Robert K. Siegel states: 1. 2. I am an attorney with Jacob & Weingarten, P.C. (J&W). J&W is submitting this disclosure pursuant to

F.R.Bankr.P. 2019(a) because it represents more than one creditor (the Creditors) in this case. 3. The names and addresses of the Creditors are: a. Exxon Mobil Chemical Company, a division of Exxon

Mobil Corporation (Exxon), whose address is 13501 Katy Freeway, Houston, TX 77079; b. Mytex Polymers, G.P. (Mytex), whose address is

13501 Katy Freeway, Houston, TX 77079; c. Kimsworth, Inc. (Kimsworth), whose address is 3333

New Hyde Park Rd., P.O. Box 5020, New Hyde Park, N.Y. 110420020; and d. Third Avenue Management L.L.C., which, upon

information and belief, is the investment advisor to the Third Avenue Trust, which issues a series of shares including the Third Avenue Value Fund Series, one or more of which

(collectively, Third Avenue) are creditors, whose address is 622 Third Avenue, 32nd Floor, N.Y., N.Y. 10017.

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4.

The

nature

and

amount

of

the

claims

(and

time

of

acquisition) of the Creditors are:1 a. Exxon: Upon information and belief, Exxon filed a

proof of claim against Collins & Aikman Corporation, in case No. 05-55927, in which it asserted an unsecured priority claim of $271,100.14 and an unsecured non-priority claim of

$8,069,458.18. Upon information and belief, the basis for Exxons claim is for goods sold. I am not aware of the time that Exxon acquired such claims. b. Mytex: Upon information and belief, Mytex filed a

proof of claim against Collins & Aikman Corporation, in case No. 05-55927, in which it asserted an unsecured priority claim of $48,457.96 and an unsecured non-priority claim of

$803,524.92. Upon information and belief, the basis for the claim is for goods sold. I am not aware of the time that Mytex acquired such claims. c. Kimsworth: Kimsworth filed a proof of claim against

Collins & Aikman Products Co., in case No. 05-55932, in which it asserted an unsecured non-priority claim of $156,521.98. The basis for the claim is the amount owing under a

nonresidential real property lease (the Lease), including a lease rejection claim. Upon information and belief, the claim was incurred from February 1, 2005 through the petition date.

Unless stated, J&W is unaware of the date(s) on which the Creditors claims were acquired. Additionally, the information being disclosed herein is solely for the purpose of making the disclosure which is required by F.R.Bankr.P. 2019(a), and is not intended, nor should it be used, for any other purpose.

d.

Third Avenue: Upon information and belief, Third

Avenue purchased a series of bonds (with an interest rate of 10.75%, all due on December 31, 2011) which were issued by Collins & Aikman with cost Products total value: Co. and Collins of and & Aikman

Corporation, (amortized

maturity

values

$250,750,000 $2,000,000

$152,736,192.21)

(amortized cost value: $146,450), respectively. The trade date of the bonds which were issued by Collins & Aikman Products Co. ranged from April 12 through May 13, 2005. The trade date

of the bonds which were issued by Collins & Aikman Corporation was May 17, 2005 (i.e., the date on which Debtors filed their voluntary bankruptcy petitions). 5. The pertinent facts and circumstances in connection with

the Creditors employment of J&W are: a. Exxon: J&W has represented Exxon primarily in

connection with a reclamation claim against Collins & Aikman Corporation and Collins & Aikman Products Co. In that regard, J&W filed an adversary proceeding complaint against those debtors and objected to a motion to establish a procedure for treatment of reclamation claims. bankruptcy case for Exxon. b. Mytex: J&W has represented Mytex primarily in J&W has also monitored this

connection with a reclamation claim against Collins & Aikman Corporation and Collins & Aikman Products Co. In that regard, J&W filed an adversary proceeding complaint against those debtors and objected to a motion to establish a procedure for 3

treatment of reclamation claims. bankruptcy case for Mytex. c. Kimsworth: J&W has

J&W has also monitored this

represented

Kimsworth

in

connection with: (a) filing a motion for allowance and payment of an administrative expense claim under bankruptcy code 503(b) in connection with the Lease; and (b) preparing and filing a proof of claim. Such claims were against Collins & Aikman Products Co. d. Third Avenue: J&W is acting as local counsel to

Third Avenue in connection with objections filed by Third Avenue to certain fee applications which have been filed by various professional persons in this case. 6. J&W may perform additional services for the Creditors in

the future. 7. At no time during its employment by the Creditors has J&W

held any claim against, or interest in, any of Debtors. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, to the best of my knowledge, information and belief. JACOB & WEINGARTEN, P.C. By: /s/ Robert K. Siegel Robert K. Siegel (P36140) 2301 W. Big Beaver Rd., #777 Troy, MI 48084 (248) 649-1900 rob@jacobweingarten.com

Date: December 13, 2006

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