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

Debtors.
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Chapter 11 Case No. 05-55927-R (Jointly Administered) Tax Identification No. 13-3489233 Honorable Steven W. Rhodes

OBJECTION BY BECKER PROPERTIES, LLC TO NOTICE OF SALE OF THE DEBTORS ASSETS AT STERLING HEIGHTS, MICHIGAN FACILITY Becker Properties, LLC (Becker) objects to Notice of Sale of the Debtors Assets at Sterling Heights, Michigan Facility (Notice) [Docket #7877], because certain of the assets listed on the Notice are not owned by Debtors but rather are owned by Becker as owner of the building. Also, other assets that Debtors seek to sell can only be removed from the facility if Debtors do not cause material damage to the facility and/or repaired any damage caused to the

The Debtors in the proposed jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc.; Becker Group, LLC (d/b/a Collins & Aikman Premier Mold); Brut Plastics, Inc.; Collins & Aikman (Gibraltar) Limited; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation); Collins & Aikman Asset Services, Inc.; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.); Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.); Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.); Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.); Collins & Aikman Automotive International, Inc.; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.); Collins & Aikman Automotive Mats, LLC; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.); Collins & Aikman Automotive Services, LLC; Collins & Aikman Canada Domestic Holding Company; Collins & Aikman Carpet & Acoustics (MI), Inc.; Collins & Aikman Carpet & Acoustics (TN), Inc.; Collins & Aikman Development Company; Collins & Aikman Europe, Inc.; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.); Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.); Collins & Aikman Interiors, Inc.; Collins & Aikman International Corporation; Collins & Aikman Plastics, Inc.; Collins & Aikman Products Co.; Collins & Aikman Properties, Inc.; Comet Acoustics, Inc.; CW Management Corporation; Dura Convertible Systems, Inc.; Gamble Development Company; JPS Automotive, Inc. (d/b/a PACJ, Inc.); New Baltimore Holdings, LLC; Owosso Thermal Forming, LLC; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.); Wickes Asset Management, Inc.; and Wickes Manufacturing Company.

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facility. In support of its objection and request for related relief, Becker states as follows: 1. On May 17, 2005 (Petition Date), Debtors filed their voluntary petitions for

relief under chapter 11 of the Bankruptcy Code. 2. Debtor Collins & Aikman Products Co. and Becker are parties to a Lease

Agreement dated January 1, 2003, as amended (Lease) covering the premises located at 6600 East Fifteen Mile Road, Sterling Heights, Michigan (Leased Premises). 3. Under the Lease (paragraph 7.2), any alterations, additions, improvements and

fixtures made by Debtors that are attached to the floors, walls or ceilings of the Leased Premises (collectively, Fixtures) become the property of Becker upon termination of the Lease. The assets listed on Exhibit A (Becker Assets), which Debtors have also listed on the Notice, are Fixtures that were either at the Leased Premises when Debtors took possession or became Beckers property upon the termination of the Lease. Because the Becker Assets are not

Debtors property, the Becker Assets should not be included in the Sale or Notice. 4. Under the Lease, Debtors are obligated to remove any trade fixtures (excepted

from Fixtures) without causing material injury or damage to the Leased Premises. Debtors are also obligated to repair any damage or injury to the Leased Premises caused by Debtors use of the Leased Premises and the removal of trade fixtures or other assets in a workmanlike manner. For example, if Debtors wish to sell item #01207 (PLANT ANDON LIGHT SYSTEM), Debtors must insure that all wiring and installation conduits, and any related items, be removed properly from the Leased Presmies and any damage repaired. 5. Debtors should provide evidence of ownership satisfactory to Becker of items 2
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#001128 (5TH CRANE) and #000465 (20 TON OVERHEAD CRANE). If Debtors provide such evidence to Becker, Becker will consent to the sale of these assets, provided, however, that Debtors remove the entire rail and way systems, including uprights, and restore the building to pre-crane conditions. 6. Debtors Sale Plan & Expense Budget attached as Exhibit B to the previous

Notice filed on July 6, 2007 [Docket No. 7709] is deficient because it does not provide for the cost to repair the Leased Premises due to Debtors use of the Leased Premises and the removal of Debtors Assets. RELIEF REQUESTED Becker requests entry of an Order removing the Becker Assets from the Notice, requiring compliance with the Lease upon the removal of other items and granting any other relief the Court deems necessary. BODMAN LLP By: /s/ Robert J. Diehl, Jr. Robert J. Diehl, Jr. (P31264) Ralph E. McDowell (P39235) 6th Floor at Ford Field 1901 St. Antoine Street Detroit, Michigan 48226 Telephone: (313) 259-7777 Facsimile: (313) 393-7579 rdiehl@bodmanllp.com Attorneys for Becker Properties, L.L.C. Dated: August 2, 2007

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Exhibit A The assets listed below correspond to the Old System Numbers listed on Exhibit A to the Notice: 01343 001223 001180 001181 001329 001128 000465 SECURITY SCREEN DOORS (4) AND 11 DOOR OPENERS MODIFY NORTH CRANE FOR SLOW SPEEDS NORTHERN 40T BRIDGE CRANE NORTHERN 40T BRIDGE CRANE 45T CRANE (RESPANT INSTALLATION) 5TH CRANE 20 TON OVERHEAD CRANE

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