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) ) Debtors ) ) __________________________________________) Chapter 11 Case No. 05-55927 (Jointly Administered)

NOTICE OF APPEARANCE AND REQUEST FOR NOTICES PLEASE TAKE NOTICE that William E. Burton III and the law firm of Smith Moore LLP enter their appearance for Kayser-Roth Corporation in these cases and request, pursuant to Rules 2002, 3017, 9007 and 9010 of the Rules of Bankruptcy Procedure, that they be added to the official mailing matrix and service lists in these cases and that all notices given or required to be given in these cases and all documents served or required to be served in these cases be given to or served upon: William E. Burton III Smith Moore LLP 300 N. Greene Street, Suite 1400 Greensboro, N.C. 27420 Telephone: 336-378-5421 Telecopy: 336-433-7412 E-Mail: PLEASE TAKE FURTHER NOTICE that the foregoing request includes not only the notices and papers referred to in the Bankruptcy Rules specified above, but also includes, without limitation, any and all other orders, notices, applications, motions, petitions, pleadings, requests, complaints, demands and any other papers, whether formal or informal, written or oral, and whether transmitted or conveyed by mail, delivery, telephone, facsimile, electronically or




otherwise, which relate in any way to this case or any proceedings therein. PLEASE TAKE FURTHER NOTICE that neither this notice nor any later appearance, pleading, claim, or suit shall waive any right: (1) to challenge the jurisdiction of the Bankruptcy Court; (2) to have final orders in non-core matters entered only after de novo review by a District Court Judge; (3) to trial by jury in any proceeding so triable in this case or any case, controversy, or proceeding related to this case; (4) to have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal; or (5) to any other rights, claims, actions, defenses, setoffs, or recoupments to which Kayser-Roth Corporation is or may be entitled under agreements, in law or in equity, all of which rights, claims, actions, defenses, setoffs and recoupments are expressly reserved. This the 11th day of October, 2005. __s/ William E. Burton III______ William E. Burton III N.C. State Bar No. 19854 Attorney for Kayser-Roth Corporation OF COUNSEL: SMITH MOORE LLP 300 North Greene Street, Suite 1400 Post Office Box 21927 Greensboro, NC 27401 (27420) Telephone: (336) 378-5200 Facsimile: (336) 433-7412

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing NOTICE OF APPEARANCE AND REQUEST FOR NOTICES has been duly served upon the following parties by electronic filing and/or by depositing a copy thereof in the United States Mail, first-class, postage prepaid, addressed to the following: Joseph M. Fischer Carson Fischer, PLC 300 E. Maple Road, 3rd Floor Birmingham, MI 48009 Marion J. Mack Paul J. Randel 211 W. Fort St. Suite 700 Detroit, MI 48226 Michael S. Stamer Akin, Gump, Strauss, Hauer & Feld, LLP 590 Madison Avenue, 20th Floor New York, NY 10022 Richard M. Cieri 153 East 53rd Street New York, NY 10022-4611 This the 11th day of October, 2005. __s/ William E. Burton III_______ William E. Burton III Attorney for Kayser-Roth Corporation