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

, Debtors. __________________________________________/ Case No. 05-55927-SWR Chapter 11 Judge Rhodes (Jointly Administered)

COLLINS & AIKMAN AUTOMOTIVE CANADA INC.S MOTION FOR PAYMENT OF CHAPTER 11 ADMINISTRATIVE EXPENSE CLAIM Collins & Aikman Automotive Canada Inc. (Automotive), by its attorneys, Bernardi, Ronayne & Glusac, P.C., states: 1. This Motion is a contested matter brought pursuant to Code 503(a),

Fed.R.Bankr.P. 9014, and L.B.R. 9014-1 (E.D.M.) for purposes of the allowance of a Chapter 11 administrative expense claim. 2. This Motion is a core proceeding pursuant to 28 U.S.C. 157(b)(2)(B)

and the Court has jurisdiction pursuant to 28 U.S.C. 1334. 3. Collins & Aikman Corporation and its affiliated debtors (collectively, the

Debtors) filed a voluntary petition under Chapter 11 of the U.S. Bankruptcy Code (the Code) on May 17, 2005. 4. On or about October 12, 2007, a Notice was served in the Debtors

Chapter 11 case that, among other things, set November 12, 2007, as the last day for claimants to file and serve requests for payment of Chapter 11 administrative expense claims pursuant to Code 503(b). 5. On July 19, 2007, Automotive filed for and obtained protection from its

creditors under Canadian law, specifically the Companies Creditors Arrangement Act

0W[;'+,

0555927071112000000000073

i>

R.S.C. 1985, c. C-36, as amended (the CCAA). The terms of this proceeding are governed by an order of the Ontario Superior Court of Justice (Commercial List) dated July 19, 2007 (the Initial Order). 6. A previous order of the Ontario Superior Court of Justice (Commercial

List) dated May 15, 2007 also provided that the Chapter 11 proceedings commenced on May 17, 2005, by the Debtors (the Chapter 11 Proceedings) are recognized as a foreign proceeding as defined in the CCAA pursuant to subsection 18.6(1) of the CCAA. 7. Pursuant to the Initial Order, Ernst & Young Inc., was appointed as

monitor (the Monitor) of Automotive during their CCAA proceedings. 8. The Debtors were tier 1 automotive suppliers of major hard trim and soft

trim components of vehicle interiors. The Debtors had two primary product areas, their Soft Trim and Plastics operations. The Debtors plastics group manufactured a full range of plastics-based automotive interior products including instrument panels and instrument panel components, door panels, consoles, and other trim components as well as exterior products including front and rear bumper parts. Automotive is a wholly owned subsidiary of Debtor Collins & Aikman Products Co. (Products) and represents all of the Debtors plastics operations in Canada. 9. Automotive has generated a net loss from operations for the past several

years. As a result, Automotive requires ongoing funding in order to continue operations. On June 30, 2007, the Debtors along with their senior secured prepetition lenders entered into an agreement with Automotives primary customer, DaimlerChrysler Company LLC, to provide for continued funding of Automotives operations. In connection with

this funding arrangement, Automotive filed for and obtained protection from its creditors pursuant to the CCAA on July 19, 2007. Prior to this date, Automotives losses had been funded by companies within the Debtors family and from December 2006 to June 30, 2007, indirectly by its customers pursuant to an accommodation agreement entered into between the Debtors and its major customers. 10. The Debtors Soft Trim group manufactured a variety of automotive

carpet and acoustics products and convertible roof systems. Collins & Aikman Canada Inc. (C&A Canada), a sister company to Automotive, comprised all of the Debtors Soft Trim operations in Canada. 11. Historically, treasury operations for the Debtors were centralized.

Individual legal entities did not have separate bank accounts to deposit receipts into or from which to make disbursements. 12. The Debtors maintained six lockboxes two at JP Morgan Chase Bank in

New York, New York, and four at JP Morgan Chase Bank in Toronto, Ontario, Canada. The lockboxes in New York were in the name of Products and funds deposited into those lockboxes were automatically swept nightly into a concentration account in Products name. Of the lockboxes in Toronto, two were in the name of Products and two were in the name of Automotive. However, all funds deposited into these lockboxes were

automatically swept nightly into a concentration account in the name of C&A Canada. Customers often had a historical practice of remitting one payment for all amounts owing to the Debtors, regardless of the legal entity to which the amounts were owed. For example, a customer might remit a payment to one of the New York Products lockboxes

that included payment on account of invoices issued to it by both Products plants as well as Automotive plants. 13. Disbursements were made from one of the two concentration accounts

discussed above. Generally, all U.S. dollar denominated disbursements were made from the Products account in New York and all Canadian dollar disbursements were made from the C&A Canada account in Toronto. 14. All intercompany transactions, including intercompany sales and

purchases of raw material or work in process between Products and Automotive, the contract manufacturing fee charged by C&A Canada to Products and any corporate overhead expenses incurred by one entity and charged to another were booked in the companies intercompany accounts but not actually settled on a cash basis. As a result of this integrated cash management system, intercompany receivable and payables were generated on a day-to-day basis. 15. Given the practical difficulties that would have arisen as a result of trying

to separate the treasury functions, during their CCAA proceedings Automotive and C&A Canada separately obtained the approval of the Ontario Superior Court of Justice to continue to utilize the integrated cash management system subject to a cash management protocol requiring the Monitor to review all receipts, disbursements, and transfers of cash to ascertain which party they were made on behalf of and requiring that any resulting intercompany receivables and payables be settled on a regular basis. 16. The Monitor continues to track and reconcile the intercompany

receivables and payables that resulted from the integrated cash management system and normal course intercompany activities between Automotive, C&A Canada and the

Debtors, but a settlement of the intercompany balances has not yet occurred as certain information required by the Monitor has yet to be provided. 17. However, it appears from the reconciliations completed to date that

Automotive has a Chapter 11 administrative expense claim pursuant to Code 503(b) against the Debtors arising as a result of the aforementioned integrated cash management system, the amount of which has yet to be determined. Therefore Automotive files this administrative claim and reserves its right to amend and supplement this administrative claim once the reconciliation is completed. 18. An Order should be entered granting Automotive a Chapter 11

administrative expense claim in an amount to be determined, and requiring the Debtors and/or the Post Confirmation Trust to pay the claim within ten (10) days from their receipt of the determination of the amount of the claim owed to Automotive. THEREFORE, Automotive requests it be allowed a Chapter 11 administrative expense claim, in an amount to be determined, for the reasons previously given; that the Debtors and/or the Post Confirmation Trust be ordered to pay the claim within ten (10) days from their receipt of the determination of the amount of the claim owed to Automotive; and for any other relief that is just and equitable under the circumstances. BERNARDI, RONAYNE & GLUSAC, P.C.

Dated: November 12, 2007

/s/Rodney M. Glusac Attorneys for Collins & Aikman Automotive Canada Inc. 1058 Maple Street Suite 100 Plymouth, MI 48170 (734) 416-1780 rodg@brgpc.com (P43756)

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In Re: COLLINS & AIKMAN CORPORATION, et al., Debtors. __________________________________________/ Case No. 05-55927-SWR Chapter 11 Judge Rhodes (Jointly Administered)

ORDER GRANTING COLLINS & AIKMAN AUTOMOTIVE CANADA INC.S MOTION FOR PAYMENT OF CHAPTER 11 ADMINISTRATIVE EXPENSE CLAIM Collins & Aikman Automotive Canada Inc. (Automotive), having filed its Motion for Payment of Chapter 11 Administrative Expense Claim (the Motion); Automotive having properly served the Motion; no objections to the Motion having been timely filed; and the Court being duly advised in the premises: IT IS ORDERED that the Motion is granted. IT IS FURTHER ORDERED that Automotive has an allowed Chapter 11 administrative expense claim pursuant to 11 U.S.C. 503(b) in an amount to be determined. IT IS FURTHER ORDERED that within ten (10) days from their receipt of the determination of the amount of the Chapter 11 administrative expense claim owed to Automotive, the Debtors and/or the Post Confirmation Trust shall pay Automotive, the amount due and owing.

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In Re: COLLINS & AIKMAN CORPORATION, et al., Debtors. __________________________________________/ Case No. 05-55927-SWR Chapter 11 Judge Rhodes (Jointly Administered)

NOTICE OF COLLINS & AIKMAN AUTOMOTIVE CANADA INC.S MOTION FOR PAYMENT OF CHAPTER 11 ADMINISTRATIVE EXPENSE CLAIM Collins & Aikman Automotive Canada Inc. (Automotive) has filed its Motion for Payment of Chapter 11 Administrative Expense Claim, requesting the entry of an order authorizing the Debtors and/or the Post Confirmation Trust to pay Automotive a Chapter 11 administrative expense claim within ten (10) days from their receipt of the determination of the amount of the Chapter 11 administrative expense claim owed to Automotive. Your rights may be affected. You should read these papers carefully and discuss them with your attorney, if you have one. If you do not want the Court to grant the relief sought in the Motion or if you want the Court to consider your views on the Motion, within 15 days you or your attorney must: 1. File with the Court a written response or objection, explaining your position, at: 1 U.S. Bankruptcy Court 211 W. Fort Street Suite 2100 Detroit, Michigan 48236 If you mail your response to the court for filing, you must mail it early enough so that the court will receive it on or before the date stated above.

You must also mail a copy to:

Response or answer must comply with F. R. Civ. P. 8(b), (c) and (e)

Rodney M. Glusac, Esq. Bernardi, Ronayne & Glusac, P.C. 1058 Maple Street Suite 100 Plymouth, MI 48170 and to: Ashley John Taylor Stikeman Elliott LLP 5300 Commerce Court West 199 Bay Street Toronto, ON M5L 1B9 2. If a response or objection is timely filed and served, the clerk will schedule a hearing on the motion and you will be served with a notice of the date, time and location of the hearing.

If you or your attorney do not take these steps, the Court may deem that you do not oppose the relief sought in the Motion and may enter an Order granting that relief.

BERNARDI, RONAYNE & GLUSAC, P.C. /s/Rodney M. Glusac Attorneys for Collins & Aikman Automotive Canada Inc. 1058 Maple Street Suite 100 Plymouth, MI 48170 (734) 416-1780 rodg@brgpc.com (P43756) Dated: November 12, 2007

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In Re: COLLINS & AIKMAN CORPORATION, et al., Debtors. __________________________________________/ Case No. 05-55927-SWR Chapter 11 Judge Rhodes (Jointly Administered)

CERTIFICATE OF SERVICE I certify that on November 12, 2007, I electronically filed Collins & Aikman Automotive Canada Inc.s Motion for Payment of Chapter 11 Administrative Expense Claim (the Motion) and the Notice of the Motion (the Pleadings) with the Clerk of the Court using the ECF system, which will send notification of such filing to the following: Neil Burger, Esq.: neilberger@teamtogut.com Office of the U.S. Trustee All Attorneys of Record and I certify that on November 12, 2007, I have mailed by United States Postal Service the Pleadings to the non-ECF participants: Richard M. Cieri Kirkland & Ellis LLP Citigroup Center 153 East 53rd Street New York, NY 10022 David L. Eaton Ray C. Schrock Scott R. Zemnick Kirkland & Ellis LLP 200 East Randolph Drive Chicago, IL 60601 Stephen E. Spence U.S. Department of Justice Office of the U.S. Trustee 211 W. Fort Street, Suite 700 Detroit, MI 48226 Michael S. Stamer Philip C. Dublin Akin Gump Strauss Hauer & Feld LLP 590 Madison Avenue New York, NY 10022

Joseph M. Fischer Lawrence A. Lichtman Carson Fischer, P.L.C. 4111 West Andover Road Second Floor Bloomfield Hills, MI 48302 Peter Chadwick Peter Nurge Capstone Advisory Group, LLC 1875 I Street, NW Suite 500 Washington, D.C. 20006

Thomas B. Radom Butzel Long, P.C. 100 Bloomfield Hills Parkway Bloomfield Hills, MI 48304

Harold S. Novikoff Gregory E. Pessin Wachtell, Lipton, Rosen & Katz 51 West 52nd Street New York, NY 10019

BERNARDI, RONAYNE & GLUSAC, P.C. s/Rodney M. Glusac Attorneys for Collins & Aikman Automotive Canada Inc. 1058 Maple Street Suite 100 Plymouth, MI 48170 (734) 416-1780 rodg@brgpc.com (P43756) Dated: November 12, 2007