UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN (Southern Division)

In re COLLINS & AIKMAN CORPORATION, et al. Debtors

) ) ) ) ) )

No. 05-55927 (SWR) (Chapter 11) Jointly Administered Tax ID No. 13-3489233

RESPONSE OF SHAWMUT CORPORATION TO THE COLLINS & AIKMAN LITIGATION TRUST AND POST-CONSUMMATION TRUSTS FIRST JOINT OMNIBUS OBJECTION TO CLAIMS (AMEND AND ALLOW CLAIMS) Shawmut Corporation, a secured and unsecured creditor of the Debtors, hereby responds to The Collins & Aikman Litigation Trust and Post-Consummation Trusts First Joint Omnibus Objection to Claims (Amend and Allow Claims) (the Trusts; the First Joint Objection). Shawmuts claim no. 34111 appears to have been subjected to a boilerplate objection. The sole purported ground for objection is that there is no support in the books and records of Debtor to support the Claimants request for classifying their claims as priority or secured claims. The First Joint Objection at 1-2.

A true and correct copy of Shawmuts claim no. 3411 is attached hereto (Exhibit 1), showing the following: Shawmut A/R (due to Shawmut) (See Exhibit A to attached claim no. 3411)

$119,284.54 38,187.15 273,652.46 431,124.15

Shawmut A/P (due from Shawmut) (See Exhibit B to attached to claim no. 3411) 132,445.56 186,656.47 79,601.33 28,251.12 -(426,954.48) (amount of Shawmut setoff) $4,169.67 Shawmuts unsecured claim

0W[;($$
0555927080404000000000021

53

Nowhere in The First Objection do the Trusts offer any specific facts to support their requested relief. Instead there is a bald assertion that (i) the secured portion of Shawmuts claim no. 3411 should be reduced from the as filed (with supporting documentary evidence) amount of $426,954.48 to an as allowed amount of $343,020.96, an unexplained reduction to Shawmuts detriment of $83,933.52, and (ii) the unsecured portion of Shawmuts claim no. 3411 should be reduced from the as filed (with supporting documentary evidence) amount of $4,169.67 to zero. The Trusts objection to Shawmuts documented claim no. 3411 is unsupported by any facts. CONCLUSION For all the foregoing reasons, the Trusts objection to Shawmuts claim no. 3411 should be overruled, Shawmuts claim no. 3411 should be allowed in its full as filed secured and unsecured amounts of $426,954.48 (secured) and $4,169.67 (unsecured), and Shawmut should be accorded all such other and further relief as may be just.

Signature on next page

-2-

Respectfully submitted, SHAWMUT CORPORATION (formerly doing business as Shawmut Mills) By its attorneys: ERMAN TEICHER MILLER ZUCKER & FREEDMAN, P.C. /s/ Julie Beth Teicher Julie Beth Teicher (P34300) Attorneys for Shawmut Corporation 400 Galleria Officentre, Suite 444 Southfield Michigan 48034 Telephone 248 827 4100 jteicher@ermanteicher.com

Dated: April 4, 2008

Of counsel: Peter Nils Baylor (BBO 033920) Nutter, McClennen & Fish, LLP World Trade Center West 155 Seaport Boulevard Boston, MA 02210-2604 (617) 439-2000

F:\CHAP11\Collins & Aikman\Shawmut\Shawmut Response to Objection with signature block.DOC

-3-