THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION - DETROIT In re: COLLINS & AIKMAN

CORPORATION, et al., Debtors. ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Hon. Steven W. Rhodes

RESPONSE OF AT&T CORP. TO THE COLLINS & AIKMAN LITIGATION TRUST'S FIFTIETH AND FIFTY-THIRD OMNIBUS OBJECTIONS TO CLAIMS (INSUFFICIENT BOOKS AND RECORDS) AT&T Corp. ("AT&T"), by and through its undersigned counsel, hereby submits this response (the "Response") to the Collins & Aikman Litigation Trust's (the "Trust") Fiftieth and Fifty-Third Omnibus Objections to Claims (Insufficient Books and Records) (collectively, the "Objections"), and respectfully represents as follows: BACKGROUND 1. On May 17, 2005 (the "Petition Date"), the above-captioned debtors (the

"Debtors") filed voluntary petitions for relief under chapter 11 of title 11 of the United States Code (the Bankruptcy Code). 2. Prior to the Petition Date, AT&T provided telecommunications and related

services to the Debtors. 3. On or about November 14, 2005, AT&T filed (i) proof of claim number

1636 (Claim 1636) asserting an unsecured claim against one of the Debtors in the amount of $441,401.72, and (ii) proof of claim number 1637 ("Claim 1637" and together with Claim 1636, the "AT&T Claims") asserting an unsecured claim against one of the Debtors in the amount of $53,161.30.

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On July 18, 2007, the Bankruptcy Court confirmed the Debtors First

Amended Joint Plan (the Plan). 5. On or about June 27, 2008, the Trust filed the Objections pursuant to

which the Trust objected to the AT&T Claims seeking to (i) reduce the amount of Claim 1636 from $441,401.72 to $320,992.76, and (ii) disallow Claim 1637 -- on the grounds that the filed amounts of the AT&T Claims are not supported by the Debtors' books and records. RESPONSE 6. AT&T contests the Debtors' attempt to reduce Claim 1636 and disallow

Claim 1637 on the purported grounds that the amounts set forth in the AT&T Claims are not supported by the Debtors' books and records. During the course of AT&T's relationship with the Debtors, AT&T has sent and the Debtors have received, in the ordinary course of business between the parties, the invoices supporting the amounts of the AT&T Claims. Thus it is simply improper for the Trust to assert that the AT&T Claims amounts are not substantiated by the Debtors' books and records. 7. Additionally, counsel for AT&T is in the process of scanning the invoices

supporting the AT&T Claims -- which are contained in seven (7) boxes -- onto disks and will be sending them to the Trust simultaneously with this filing. 8. Accordingly, AT&T respectfully requests that the Objections be

overruled. In the alternative, AT&T respectfully requests that the hearing on the Objections be adjourned so as to allow the parties to work towards reconciliation of the AT&T Claims.

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WHEREFORE, AT&T respectfully requests that the Court (i) overrule the Objections, or alternatively, adjourn the hearing on the Objections, and (ii) grant such other and further relief as is just and proper. Dated: July 28, 2008 Respectfully submitted, By: /s/ Donna J. Lehl Donna J. Lehl, Esq. GOLD, LANGE & MAJOROS, P.C. 24901 Northwestern Highway -- Suite 444 Southfield, Michigan 48075 Telephone: (248) 350-8220 Facsimile: (248) 350-0519 (P40013) -andVincent A. DAgostino, Esq. Eric H. Horn, Esq. LOWENSTEIN SANDLER PC 65 Livingston Avenue Roseland, New Jersey 07068 Telephone: (973) 597-2500 Facsimile: (973) 597-2400 Counsel to AT&T

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

Debtor. /

Chapter 11 (Jointly Administered) Case No. 05-55927(swr) Hon. Steven W. Rhodes

CERTIFICATE OF SERVICE Donna J. Lehl, hereby certifies that on July 28, 2008, she electronically filed Response Of A T&T Corp. to the Collins & Aikman Litigation Trust's Fiftieth And Fifty-Third Omnibus Objections To Claims (Insufficient Books And Records) and Certificate of Service of the same with the Clerk of the Court using the ECF system which will send notification of such filing to the participants in the system including the following: H. William Burdett Special Counsel for the Collins & Aikman Litigation Trust Burdett@boyleburdett.com /s/ Donna J. Lehl DONNA J. LEHL (P40013) Gold, Lange & Majoros, P.C. 24901 Northwestern Highway #444 Southfield, Michigan 48075 (248) 350-8220 e-mail: dlehl@glmpc.com (P40013) Dated: July 28, 2008
E:\GLM CLIENTS - CH7 2005\Collins & Aikman\COS response to claims objection.wpd