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

, ) a Delaware corporation, ) ) Debtor. ) )

Chapter 11 Case No. 05-55927-SWR Hon. Steven W. Rhodes

LIMITED OBJECTION OF HALLMARK TOOLS TO GENERAL MOTORS CORPORATIONS MOTION FOR CONTINGENT RELIEF FROM AUTOMATIC STAY TO OBTAIN POSSESSION OF TOOLING Hallmark Tools, a division of Hallmark Technologies, Inc. (Hallmark), for its Limited Objection to General Motors Corporations Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling (the Motion) states: 1. Motion. 2. Contained in the Motion are representations by GM that: i.) GM owns the Tooling; Motion at 16, 32. ii.) the Debtor has no equity in the Tooling; Motion at 41. iii.) GM has paid the Debtor for the Tooling. Motion at 18-24, 30-31. iv.) to the best of GMs knowledge, no other parties are known to claim a valid interest in the Tooling. Motion at 26. 3. Hallmark owns certain molds (Hallmark Molds) that it is in the process of On September 2, 2005, General Motors Corporation (GM) filed the

fabricating for the Debtor. In addition, Hallmark also claims a lien on certain molds pursuant to a statute commonly known as the Michigan Mold Lien Act, MCL 445.611 et

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seq. (the Act), that it fabricated for the Debtor (and which are in try-outs) that are used to manufacture parts for GM vehicles and believes that some or all of the Hallmark Molds may be included in the tooling referenced in the Motion of which GM proposes to take possession from the Debtor. 4. Pursuant to the Act, prior to shipping the Hallmark Molds to the Debtor,

Hallmark properly affixed its name and address on the Molds. 5. Hallmark filed UCC-1 financing statements relative to the Hallmark Molds

as required by the Act. 6. Hallmark has an ownership interest in the Hallmark Molds; alternatively, it

has a statutory lien against the Hallmark Molds. 7. The Motion fails to recognize Hallmarks ownership interest/statutory lien

on the Hallmark Molds and to provide for payment to satisfy Hallmarks lien on the Hallmark Molds. 8. According to GMs supporting documentation attached to the Motion,

Hallmark believes that GM may have paid the Debtor for the Hallmark Molds, yet Hallmark has not been paid by the Debtor for the Hallmark Molds. 9. Hallmark objects to GMs requested relief to the extent that Hallmarks

ownership interest/statutory lien on the Hallmark Molds is not recognized and/or satisfied. 10. Hallmark does not object to the proposed relief requested by GM relative

to molds and tools other than the Hallmark Molds. THEREFORE, Hallmark respectfully requests that the Court deny General Motors Corporations Motion for Contingent Relief from Automatic Stay to Obtain

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Possession of Tooling to the extent that it fails to recognize and satisfy Hallmarks ownership interest/statutory lien on the Hallmark Molds and grant such further and additional relief as deemed just and proper. Respectfully submitted,

________/s/ Dennis W. Loughlin____ LYNN M. BRIMER (P43291) DENNIS W. LOUGHLIN (P57084) Attorneys for Hallmark Technologies RAYMOND & PROKOP, P.C. 26300 Northwestern Hwy, 4th Floor P.O. Box 5058 Southfield, MI 48086-5058 (248) 357-3010; fax (248) 357-2720 Dated: September 20, 2005

ECF Certificate of Service I hereby certify that on September 20, 2005, I electronically filed Limited Objection of Hallmark Tools to General Motors Corporations Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling with the Clerk of the Court using the ECF system which will send notification of such filing to: attorneys of record, and I hereby certify that I have mailed by US Postal Service the paper to the non-ECF participants. By: /s/ Dennis W. Loughlin Dennis W. Loughlin (P57084) 26300 Northwestern Hwy., 4th Floor P.O. Box 5058 Southfield, MI 48076-5058 (248) 357-3010 dloughlin@raypro.com

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