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

et al.1 Debtors. ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

EX PARTE MOTION FOR ORDER SHORTENING NOTICE PERIOD AND SCHEDULING AN EXPEDITED HEARING ON: DEBTORS MOTION FOR AN ORDER AUTHORIZING THE DEBTORS TO ENTER INTO A NEW LEASE FOR CORPORATE HEADQUARTERS The above-captioned debtors (collectively, the Debtors), in support of their ex parte motion for order shortening notice period and scheduling an expedited hearing (the Ex Parte Motion) on the Debtors motion for an order authorizing the Debtors to enter into a

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

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new lease for corporate headquarters (the New Headquarters Lease Motion) respectfully state as follows:2 Jurisdiction 1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. 1334. This

matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). 2. 3. Venue is proper pursuant to 28 U.S.C. 1408 and 1409. The statutory bases for the relief requested herein are Rules 9006 and 9007 of the

Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules) and Rule 9006-1(b) of the Local Rules of the United States Bankruptcy Court, Eastern District of Michigan. Background 4. for relief On May 17, 2005 (the Petition Date), the Debtors filed their voluntary petitions under chapter 11 of the Bankruptcy Code, 11 U.S.C. 101-1330

(the Bankruptcy Code).

The Debtors are operating their businesses and managing their

properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these cases. On the

Petition Date, the Court entered an order jointly administering these cases pursuant to Bankruptcy Rule 1015(b). 5. On May 24, 2005, the United States trustee appointed an official committee of

unsecured creditors pursuant to section 1102 of the Bankruptcy Code.

Capitalized terms used but not otherwise defined in this Ex Parte Motion have the New Headquarters Lease Motion.

meanings set forth in the

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6.

Contemporaneously with the filing of this Ex Parte Motion, the Debtors filed the

New Headquarters Lease Motion, seeking Court authority to enter into a new corporate headquarters lease with Ttrett Associates, LLC (the New Headquarters Lease). Relief Requested 7. The Debtors request that, pursuant to Bankruptcy Rule 9006(c) and Local Rule

9006-1(b), the Court shorten the notice period for objecting or otherwise responding to the New Headquarters Lease Motion to March 6, 2006 at 4:00 p.m., prevailing Eastern Time, and schedule the New Headquarters Motion to be heard on March 9, 2006 at 2:00 p.m., prevailing Eastern Time, or as soon thereafter as counsel may be heard. 8. Importantly, neither the Committee nor the prepetition secured lenders object to

having this matter heard on an expedited basis. Basis for Relief 9. As set forth in more detail in the New Headquarters Lease Motion, the Debtors

decided to pursue a new location for their headquarters. After extensive negotiations with several potential lessors and a thorough analysis of the terms of several proposed leases, the Debtors determined that the New Headquarters Lease was the most beneficial option for the Debtors and their estates. 10. As a condition to the New Headquarters Lease, Ttrett Associates, LLC (Ttrett)

is required to make substantial alterations to the location of the Debtors new headquarters, which will substantially facilitate the Debtors operations at the new headquarters. Though Ttrett is ready to make the requisite alterations, it is not willing to do so until it has been assured that the Court will approve the New Headquarters Lease. Additionally, Ttrett needs time to ensure it can deliver the premises in time for the Debtors to move without any delay or problems. Accordingly, the Debtors are requesting an expedited notice period and hearing to provide Ttrett 3
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with sufficient time to make the necessary alterations to the Debtors new headquarters, so that the Debtors may expeditiously move into such headquarters to obtain the benefits of the New Headquarters Lease. 11. Pursuant to Bankruptcy Rule 9007, the Court has authority to regulate the time

within which, the entities to whom and the form and matter in which, notice shall be given, which includes the authority to determine appropriate notice for conducting a hearing on the matters presented by the New Headquarters Lease Motion. 12. For the reasons set forth above and in the New Headquarters Lease Motion, good

and sufficient cause exists to consider the New Headquarters Lease Motion on an expedited basis as set forth herein.

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WHEREFORE, the Debtors respectfully request the entry of an order, substantially in the form attached hereto as Exhibit A, (a) shortening the period for objecting or otherwise responding to the New Headquarters Lease Motion to March 6, 2006 at 4:00 p.m., prevailing Eastern Time, (b) scheduling an expedited hearing on the

New Headquarters Lease Motion for March 9, 2006 at 2:00 p.m., prevailing Eastern Time, or as soon thereafter as counsel may be heard and (c) granting such other and further relief as this Court deems appropriate. Dated: March 1, 2006 KIRKLAND & ELLIS LLP /s/ Marc J. Carmel Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 4111 West Andover Road West - Second Floor Bloomfield Hills, Michigan 48302 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

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EXHIBIT A

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IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION, et al.1 Debtors. ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

ORDER SHORTENING NOTICE PERIOD AND SCHEDULING AN EXPEDITED HEARING ON: DEBTORS MOTION FOR AN ORDER AUTHORIZING THE DEBTORS TO ENTER INTO A NEW LEASE FOR CORPORATE HEADQUARTERS Upon the ex parte motion for order shortening notice period and scheduling an expedited hearing (the Ex Parte Motion) on the Debtors motion for an order authorizing the Debtors to enter into a new lease for corporate headquarters

(the New Headquarters Lease Motion);2 it appearing that the Court has jurisdiction over this
1

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968. Capitalized terms used but not otherwise defined in this Order have the meanings set forth in the New Headquarters Lease Motion.

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matter pursuant to 28 U.S.C. 157 and 1334; it appearing that this proceeding is a core proceeding pursuant to 28 U.S.C. 157(b)(2); it appearing that venue of this proceeding and the Ex Parte Motion in this District is proper pursuant to 28 U.S.C. 1408 and 1409; notice of the Ex Parte Motion and the opportunity for a hearing on the Ex Parte Motion was appropriate under the particular circumstances and that no other or further notice need by given; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED 1. 2. The Ex Parte Motion is granted in its entirety. A hearing on the New Headquarters Lease Motion will be conducted before the

Honorable Steven W. Rhodes, on March 9, 2006 at 2:00 p.m., prevailing Eastern Time, or as soon thereafter as counsel may be heard in the United States Bankruptcy Courthouse, 211 W. Fort Street, Detroit, Michigan 48226. 3. The objection deadline for the relief requested by the Debtors in the

New Headquarters Lease Motion shall be March 6, 2006 at 4:00 p.m., prevailing Eastern Time. 4. The Debtors shall immediately serve a copy of this Order and the

New Headquarters Lease Motion upon the Core Group, the Primary Service List and Ttrett Associates, LLC.3 5. The Debtors are authorized and empowered to take all actions necessary to

implement the relief granted in this Order. 6. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry.

Capitalized terms used in this paragraph 4 not otherwise defined herein shall have the meanings set forth in the First Amended Notice, Case Management and Administrative Procedures [Docket No. 294].

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7.

The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order.

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