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UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MICHIGAN In Re: Case No.

05-55927 (SWR) (Jointly Administered) COLLINS & AIKMAN CORPORATION, et al. Debtor. / LIMITED OBJECTION TO ENTRY OF ORDERS GRANTING SALE MOTIONS FOR SALE OF ASSETS OF INTERIOR PLASTICS GROUP AND FOR CARPET AND ACOUSTICS BUSINESS NOW COMES the Inmet Division of Multimatic (Respondent), and states: 1. Respondent is a creditor of C & A Canada, and is owed no less than Chapter 11 Hon. Steven W. Rhodes

$5,049,493.00 (CAD). 2. Upon information and belief, C & A Canada is wholly owned by one of

the chapter 11 debtors before this Court. 3. The motions to sell assets of the Interior Plastics Group and the Carpet and

Acoustics Business (the Sale Motions) appear to contemplate that all entities will be enjoined from pursuing the purchaser of these assets (Purchaser) and the purchased assets (Purchased Assets). 4. The Sale Motions, accompanying proposed Orders (the Sale Orders),

and related asset purchase agreements (collectively, the Sale Pleadings), appear to contemplate that assets of C & A Canada (Canadian Assets) will also be sold to the purchaser of the Debtors assets and that these Canadian Assets will be included within the definition of Purchased Assets. As previously indicated, the proposed Sale Orders

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appear to contemplate that all entities will be enjoined from pursuing the Purchaser and the Purchased Assets. 5. Respondent has reasonable grounds for insecurity as to whether C & A

Canada will be able to honor its obligations to Respondent. The Sale Pleadings do not provide for the creditors of C & A Canada to be paid. Moreover, the Sale Pleadings impair Respondents recourse to the Canadian Assets and the purchaser of those assets. Furthermore, C & A Canadas ability to repay its creditors will be also be affected by the sale of its assets. 6. Entry of the Sale Orders as currently drafted would be improper for

several reasons. Absent entry of the Sale Orders, Respondent would have recourse pursuant to, inter alia, the Ontario Bulk Sales Act and the Ontario Fraudulent Conveyances Act to assert that the sale of the Canadian Assets was an improper bulk sale or a fraudulent transfer [in that the creditors of C & A Canada are not being paid, while C & A Canadas shareholder and its shareholders creditors are receiving the sale proceeds]. 7. Entry of the Sale Orders does not accommodate Respondents legitimate

concerns, and would be improper because it violates nonbankruptcy law. There are no provisions in the Bankruptcy Code which would allow a sale in violation of these particular Canadian laws. Moreover, the relief requested by Debtors in the Sale Orders

is beyond the subject matter jurisdiction of a Bankruptcy Court. WHEREFORE, this Court should not enter the Sale Orders as currently drafted, and should grant Respondent such further relief as this Court deems just.

Respectfully Submitted, KEMP, KLEIN, UMPHREY, ENDELMAN & MAY, P.C. _/s/ Robert Bassel Robert N. Bassel (P48420) Attorney for Multimatic P. O. Box 4300 Troy, MI 48099-4300 (248) 528-1111 Dated: 5.4.07

UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MICHIGAN In Re: Case No. 05-55927 (SWR) (Jointly Administered) COLLINS & AIKMAN CORPORATION, et al. Debtor. / PROOF OF SERVICE The undersigned states that on 5.4.07, he filed the above document through the ECF system which is designed to serve all counsel of record for all parties in interest. A copy of the most recent listing of counsel of record is voluminous, and available at the Courts ECF website. Chapter 11 Hon. Steven W. Rhodes

Respectfully Submitted, KEMP, KLEIN, UMPHREY, ENDELMAN & MAY, P.C. _/s/ Robert Bassel Robert N. Bassel (P48420) Attorney for Multimatic P. O. Box 4300 Troy, MI 48099-4300 (248) 528-1111 Dated: 5.4.07

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