IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION

WANDA PATTERSON, et al. PLAINTIFFS, vs. HEARTLAND INDUSTRIAL PARTNERS, LLP, et al. DEFENDANTS.

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CASE NO.: 5:03CV1596 JUDGE DOWD

COMPANY D EFENDANTS ANSWER AND AFFIRMATIVE D EFENSES TO PLAINTIFFS COMPLAINT

Defendants Heartland Industrial Partners, LLP, Collins & Aikman Corporation, Collins & Aikman Products Co. and Collins & Aikman Accessory Mats. Inc. (incorrectly identified in the Complaint as Collins & Aikman Products Co.) (hereinafter collectively referred to as Company Defendants) for their Answer and Affirmative Defenses to Plaintiffs Complaint state as follows. RESPONSE TO PLAINTIFFS PRELIMINARY S TATEMENT First Paragraph. Company Defendants admit that Plaintiffs purport to be bringing this action for declaratory and injunctive relief under Section 186 of the Labor Management Relations Act (29 U.S.C. 186) and that such statute prohibits an employer from delivering certain things of value to a labor organization or its agents, and also prohibits a labor organization or its agents from requesting or receiving certain things of value from an employer. Except as specifically admitted herein, Company Defendants state that the remaining

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allegations in the first paragraph of Plaintiffs Preliminary Statement state general conclusions of law which may or may not be accurate and/or applicable in this case and therefore deny them. Second Paragraph. Company Defendants admit that Heartland Industrial Partners LLP (Heartland) is a private investment firm whose primary purpose is to buy, rebuild and expand industrial manufacturing companies in the Midwestern United States. Company Defendants further admit that on November 27, 2000 Heartland and the United Steelworkers of America, AFL-CIO (USWA or Union) entered into two documents: (1) a letter agreement setting forth their mutual understandings and commitments in furtherance of their constructive and harmonious labor relationship (the Side Letter); and (2) Exhibit I to the Side Letter, a Framework for a Constructive Collective Bargaining Relationship (the Framework). Further answering, Company Defendants state that the terms of the Side Letter and Framework (which were attached to Plaintiffs Complaint as Exhibit 1) speak for themselves. Except as specifically admitted herein, Company Defendants deny the remaining allegations in the second paragraph of Plaintiffs Preliminary Statement. Third Paragraph. Company Defendants deny the allegations in the third paragraph of Plaintiffs Preliminary Statement. Further answering, Company Defendants state that the terms and conditions of the Side Letter and Framework speak for themselves and demonstrate that Plaintiffs allegations regarding the documents are disingenuous and inaccurate. Fourth Paragraph. Company Defendants deny that Heartland has provided significant financial assistance and/or delivered to the USWA and its officials any things of value as that phrase is used under 29 U.S.C. 186 or within the Complaint. Company Defendants also deny the remaining allegations in the fourth paragraph of Plaintiffs Preliminary Statement because they are disingenuous and/or inaccurate and state that the terms and conditions of the Side Letter and Framework speak for themselves.
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Fifth Paragraph. Company Defendants admit that in the first quarter of 2001 Heartland invested in Collins & Aikman Corporation (which manufactures automotive interior components and other products) in such a manner as to acquire control over it and make it a Covered Business Enterprise or CBE as defined in the Side Letter and Framework. Company

Defendants also admit that on or about January 8, 2003, Collins & Aikman Corporation (hereinafter Collins & Aikman) and the USWA entered into a side letter and framework that are similar but not identical to the Side Letter and Framework between Heartland and the USWA. Except as specifically admitted herein, Company Defendants deny the remaining

allegations in the fifth paragraph of Plaintiffs Preliminary Statement. Sixth Paragraph. Company Defendants admit that Plaintiffs are employees of Collins & Aikman Accessory Mats. Inc. (hereinafter Accessory Mats.) in Ho lmesville, Ohio, which is a subsidiary of Collins & Aikman Products Co. Except as specifically admitted herein, Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the remaining allegations in the sixth paragraph of Plaintiffs Preliminary Statement and therefore deny them. Seventh Paragraph. The allegations in the seventh paragraph of Plaintiffs Preliminary Statement constitute legal conclusions with respect to which no answer is required. Nevertheless, Company Defendants deny the accuracy of Plaintiffs legal conclusions, state that such legal conclusions are incorrect and further state that neither the Side Letter and Framework nor any other actions of any Company Defendant constitute a violation of 29 U.S.C. 186. Company Defendants expressly deny any and all allegations set forth in Plaintiffs Preliminary Statement except to the extent they are specifically admitted above.

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JURISDICTION AND VENUE 1. Company Defendants admit that Plaintiffs claim they are bringing this action

under 29 U.S.C. 186 and that Plaintiffs are invoking this Courts jurisdiction pursuant to 29 U.S.C. 186(c) and 28 U.S.C. 1331. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 1 of Plaintiffs Complaint and specifically deny that this Court has subject matter jurisdiction over this case. 2. Company Defendants state that the allegations in paragraph 2 of the Complaint Further

constitute legal conclusions not requiring an answer and therefore deny them.

answering, Company Defendants specifically deny that this is a case of actual controversy in which Plaintiffs may obtain the declaratory and injunctive relief they are seeking. 3. Company Defendants admit that Plaintiffs claim venue is proper in this Court

pursuant to 28 U.S.C. 1391(b), 1391(c) and 1392(a) and further admit that Company Defendants transact certain business in this judicial district. Except as specifically admitted herein, Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations in paragraph 3 of Plaintiffs Complaint and therefore deny them. PARTIES 4. Company Defendants admit that Collins & Aikman, among other things, is

engaged in the business of the design, engineering and manufacturing of automotive interior components, that Collins & Aikman and certain of its subsidiaries are engaged in an industry affecting commerce and are employers as that term is used in 29 U.S.C. 186. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 4 of Plaintiffs Complaint.

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5.

Company Defendants admit that Collins & Aikman is engaged in an industry

affecting commerce and is an employer as those terms are used in 29 U.S.C. 186 and further admit that Collins & Aikman conducts certain operations through Collins & Aikman Products Co., which in turn has a subsidiary, Accessory Mats. Inc. located in Holmesville, Ohio. Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 5 of the Complaint. 6. Company Defendants admit that Plaintiffs are employees of Accessory Mats. at

its plant in Holmesville, Ohio and are employed in an industry affecting commerce. Except as specifically admitted herein, Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations in paragraph 6 of the Complaint and therefore deny them. 7. Company Defendants admit that Heartland i a private equity firm that, among s

other things, invests in, acquires, and attempts to develop industrial companies in the Midwestern United States and is engaged in an industry affecting commerce. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 7 of the Complaint. 8. Company Defendants admit that David Stockman is a founding partner of

Heartland and generally has authority to enter into contracts on behalf of Heartland. Except as specifically admitted herein, Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the remaining allegations in paragraph 8 of the Complaint and therefore deny them. 9. Company Defendants admit that Defendant USWA is a labor organization and a Except as specifically admitted herein,

union engaged in an industry affecting commerce.

Company Defendants are without sufficient knowledge or information to form a belief as to the

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truth or falsity of the remaining allegations in paragraph 9 of the Complaint and therefore deny them. 10. Company Defendants admit that George Becker is a former president of the

USWA and Leo W. Gerard is the current USWA president. Except as specifically admitted herein, Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the remaining allegations in paragraph 10 of the Complaint and therefore deny them. ALLEGED FACTS 11. Company Defendants deny that the Side Letter and Framework were secret, as

opposed to merely non-public documents, but otherwise admit the allegations in paragraph 11 of the Complaint. 12. Company Defendants admit that copies of the Side Letter and Framework,

including some extraneous markings not present on the originals, were attached as Exhibit 1 to and expressly incorporated into Plaintiffs Complaint. 13. Company Defendants deny the allegations in paragraph 13 of the Complaint.

Further answering, Company Defendants state that the terms and conditions of the Side Letter and Framework speak for themselves and do not provide the USWA and/or its officials the benefits Plaintiffs claim they provide, and further state that Plaintiffs descriptions of the Side Letter and Framework are inaccurate and disingenuous. 14. 15. 16. Company Defendants deny the allegations in paragraph 14 of the Complaint. Company Defendants deny the allegations in paragraph 15 of the Complaint. Company Defendants deny that the USWA and Union officials caused Trust and

pension fund investment in Heartland, and in entities acting on behalf of or in conjunction with Heartland, in Collins & Aikman, and in other enterprises acquired and/or invested in by
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Heartland.

Further answering, Company Defendants are without sufficient knowledge or

information to form a belief as to the truth or falsity of the remaining allegations in paragraph 16 of the Complaint and therefore deny them. 17. Company Defendants admit that certain steel industry Pension Funds, jointly

managed by the Union and Company Trustees, invested as minority investors in Heartland. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 17 of the Complaint. 18. Company Defendants deny the allegations in paragraph 18 of the Complaint.

Further answering, Company Defendants state that the terms and conditions of the Side Letter and Framework speak for themselves and the allegations in subparagraphs 18(a) through 18(h) of the Complaint are disingenuous and do not accurately describe and/or characterize the cited provisions of the Side Letter and Framework. 19. Company Defendants state that the specific commitments undertaken by the

USWA are explicitly set forth in the provisions of the Side Letter and Framework which are cited in subparagraphs 19(a) through 19(g) of the Complaint. Further answering, Company Defendants state that the provisions of the Side Letter and Framework which are cited in subparagraphs 19(a) through 19(g) of the Complaint speak for themselves. Except as

specifically admitted herein, Company Defendants deny the allegations in paragraph 19 of the Complaint. 20. Company Defendants deny the allegations in Paragraph 20 of the Complaint

insofar as they understand such allegations. Further answering, Company Defendants state that it may not be possible for them to accurately answer the allegations in paragraph 20 of the Complaint because they are too vague and ambiguous to understand what Plaintiffs are referring to.
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21.

Company Defendants state that sections 2 through 7 and 11 of the Side Letter Company Defendants further admit that under the Side Letter, if

speak for themselves.

Heartland (1) invests in another company in such a manner as to acquire majority ownership or control of such other company, and (2) after a six month period of time, and (3) upon request by the USWA, and (4) absent a number of specified exceptions, then Heartland must cause such other company to enter into agreements with the USWA that are similar but not identical to the Heartland USWA Side Letter and Framework. Except as specifically admitted herein,

Company Defendants deny the allegations in paragraph 21 of the Complaint. 22. Company Defendants admit that in the first quarter of 2001, Heartland invested in

Collins & Aikman in such a manner as to acquire ownership in and control over that company as well as authority to appoint a majority of the directors to its board of directors. Company Defendants further admit that Heartland to this day retains such ownership and controlling interest in Collins & Aikman. 23. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 23 of the Complaint because they constitute a legal conclusion and Company Defendants therefore deny them. 24. Company Defendants admit that Heartland provides certain advisory and

consulting services to Collins & Aikman. Company Defendants further admit that Heartland caused Collins & Aikman to execute documents similar but not identical to the Framework and Side Letter approximately twenty (20) months after Heartland acquired a controlling interest in Collins & Aikman. Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 24 of the Complaint both on a factual basis and because they constitute a legal conclusion.

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25.

Company Defendants admit that on or about January 8, 2003 Heartland caused

Collins & Aikman to enter into a side letter and framework agreement with the USWA that are similar but not identical to the Heartland USWA Side Letter and Framework. Company Defendants further admit that Collins & Aikman remains a party to such side letter and framework. 26. Company Defendants admit that Heartland has caused some other enterprises

which it owns and/or controls, including Metaldyne Corporation and TriMas Corporation, to become parties to certain agreements that are similar but not identical to the Heartland USWA Side Letter and Framework. Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 26 of the Complaint. 27. Company Defendants deny the allegations in paragraph 27 of the Complaint as

inaccurate. Company Defendants also note that the Side Letter, not the Framework, is the controlling document (See Side Letter at 13), that the Framework is merely an exhibit to the Side Letter, and the Framework is in fact modified in several instances by the Side Letter. 28. Company Defendants admit generally that Collins & Aikman and Heartland have

acquired other companies, including but not limited to Becker Plastics, Joan Fabrics and Tac-Trim. Complaint. 29. Company Defendants are without sufficient knowledge or information to form a Company Defendants deny the remaining allegations in paragraph 27 of the

belief as to the truth or falsity of the allegations in paragraph 29 of the Complaint and therefore deny them.

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30.

Company Defendants admit that in or about May 2003, the USWA conducted an

organizing drive at the Accessory Mats. facility in Holmesville, Ohio. Further answering, Company Defendants state that such organizing drive ended on or about August 12, 2003 without the USWA gaining majority representation or requesting recognition as the employees bargaining representative. 31. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 31 of the Complaint and therefore deny them. 32. Company Defendants admit that Heartland and Collins & Aikman have

recognized and abided by their contractual obligations under the Side Letter and Framework (or similar documents) in connection with the USWAs May August 2003 organizing drive at the Accessory Mats. facility in Holmesville, Ohio. Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 32 of the Complaint. 33. Company Defendants admit that Heartland and Collins & Aikman have abided by

and will continue to abide by their contractual obligations under the Side Letter and Framework (or similar documents) in connection with the Holmesville facility. Except as specifically

admitted herein, Company Defendants deny the remaining allegations in paragraph 33 of the Complaint. 34. Company Defendants admit that Heartland and Collins & Aikman have abided by

and will continue to abide by their contractual obligations under the Side Letter and Framework (or similar documents). Company Defendants further admit that they are aware that some employees at the Accessory Mats. Facility in Holmesville in the past have resisted and/or rejected union representation during informal union organizing drives (i.e., no actual elections

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have been held in recent years). Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 34 of the Complaint. 35. Company Defendants deny the allegations in paragraph 35 of the Complaint.

Further answering, Company Defendants state that subparagraphs 35(a) and 35(b) of the Complaint do not accurately describe or characterize the cited provisions of the Side Letter and Framework and that the terms of such documents speak for themselves. 36. Company Defendants deny the allegations in paragraph 36 of the Complaint. CLAIMS FOR R ELIEF 37. 38. Company Defendants deny the allegations in paragraph 37 of the Complaint. Company Defendants deny the allegations in paragraph 38 of the Complaint.

Further answering, Company Defendants state that the sections of the Side Letter and Framework which are cited in subparagraphs 38(a) through 38(n) of the Complaint speak for themselves and in many cases are not accurately described in the Complaint. 39. Company Defendants admit that the Plaintiffs are employed by Accessory Mats.

Except as specifically admitted herein, Company Defendants deny the remaining allegations in paragraph 39 of the Complaint. 40. 41. 42. Company Defendants deny the allegations in paragraph 40 of the Complaint. Company Defendants deny the allegations in paragraph 41 of the Complaint. Company Defendants deny the allegations in paragraph 42 of the Complaint.

Further answering, Company Defendants state that the allegations in paragraph 42 of the Complaint constitute pure speculation and/or legal conclusions to which any response other than a denial would be unwarranted.

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FIRST COUNT Company Defendants restate their answers to Plaintiffs Preliminary Statement and paragraphs 1 through 42 of the Complaint and incorporate such answers by reference as if fully rewritten herein. 43. Company Defendants admit that the USWA is the exclusive bargaining

representative of some Collins & Aikman employees and is a party to certain collective bargaining agreements with Collins & Aikman. 44. 45. Company Defendants admit the allegations in paragraph 44 of the Complaint. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 45 of the Complaint and therefore deny them. 46. Company Defendants deny the allegations in paragraph 46 of the Complaint.

Further answering, Company Defendants state that the allegations in paragraph 46 of the Complaint constitute legal conclusions to which no response is necessary. 47. 48. 49. 50. Company Defendants deny the allegations in paragraph 47 of the Complaint. Company Defendants deny the allegations in paragraph 48 of the Complaint. Company Defendants deny the allegations in paragraph 49 of the Complaint. Company Defendants deny the allegations in paragraph 50 of the Complaint. SECOND COUNT Company Defendants restate their answers to Plaintiffs Preliminary Statement and paragraphs 1 through 50 of the Complaint and incorporate such answers by reference as if fully rewritten herein. 51. Company Defendants admit that the USWA conducted an organizing drive at the

Accessory Mats. facility in Holmesville, Ohio in 2003. Except as specifically admitted herein,
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Company Defendants are without sufficient knowledge or information to form a belief as to the truth or falsity of the allegations in paragraph 51 of the Complaint and therefore deny them. 52. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 52 of the Complaint and therefore deny them. 53. 54. 55. 56. 57. Company Defendants deny the allegations in paragraph 53 of the Complaint. Company Defendants deny the allegations in paragraph 54 of the Complaint. Company Defendants deny the allegations in paragraph 55 of the Complaint. Company Defendants deny the allegations in paragraph 56 of the Complaint. Company Defendants deny the allegations in paragraph 57 of the Complaint. THIRD COUNT Company Defendants restate their answers to Plaintiffs Preliminary Statement and paragraphs 1 through 57 of the Complaint and incorporate such answers by reference as if fully rewritten herein. 58. 59. Company Defendants admit the allegations in paragraph 58 of the Complaint. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 59 of the Complaint and therefore deny them. 60. 61. Company Defendants deny the allegations in paragraph 60 of the Complaint. Company Defendants admit that Heartland and Collins & Aikman at separate

times became parties to similar but not identical versions of the Side Letter and Framework, and further admit they have abided by and will continue to abide by their contractual obligations under those documents. Except as specifically admitted herein, Company Defendants deny the

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remaining allegations in paragraph 61 of the Complaint, including the allegations in subparagraphs 61(a) through 61(d). 62. Company Defendants are without sufficient knowledge or information upon

which to form a belief as to the truth or falsity of the allegations in paragraph 62 of the Complaint and therefore deny them. 63. 64. Company Defendants deny the allegations in paragraph 63 of the Complaint. Company Defendants deny the allegations in paragraph 64 of the Complaint. FOURTH COUNT Company Defendants restate their answers to Plaintiffs Preliminary Statement and paragraphs 1 through 64 of the Complaint and incorporate such answers by reference as if fully rewritten herein. 65. Company Defendants admit that if and when Heartland invests in another

business enterprise in such a manner that Heartland obtains majority ownership or control over such other business enterprise such that it constitutes a Covered Business Enterprise or CBE as that term is defined in the Side Letter and Framework, and after six months and a request by the USWA, then Heartland, absent certain exceptions, must cause the Covered Business Enterprise to enter into a side letter and framework similar but not identical to the Heartland USWA Side Letter and Framework. Further answering, Company Defendants state that the terms of sections 2 through 7 and 11 of the Side Letter speak for themselves. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 65 of the Complaint. 66. Company Defendants deny the allega tions in paragraph 66 of the Complaint.

Further answering, Company Defendants state that section I(E) of the Framework speaks for itself.
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67.

Company Defendants deny the allegations in paragraph 67 of the Complaint.

Further answering, Company Defendants state that the allegations in paragraph 67 of the Complaint constitute legal conclusions and therefore no answer is necessary. 68. 69. 70. 71. 72. 73. 74. Company Defendants deny the allegations in paragraph 68 of the Complaint. Company Defendants deny the allegations in paragraph 69 of the Complaint. Company Defendants deny the allegations in paragraph 70 of the Complaint. Company Defendants deny the allegations in paragraph 71 of the Complaint. Company Defendants deny the allegations in paragraph 72 of the Complaint. Company Defendants deny the allegations in paragraph 73 of the Complaint. Company Defendants deny the allegations in paragraph 74 of the Complaint. FIFTH COUNT Company Defendants restate their answers to Plaintiffs Preliminary Statement and paragraphs 1 through 74 of the Complaint and incorporate such answers by reference as if fully rewritten herein. 75. Company Defendants admit that on or about January 8, 2003, Collins & Aikman

became a party to and has since maintained a side letter and framework that is similar but not identical to the Heartland Side Letter and Framework, and further admit that Collins & Aikman did so because it was a Covered Business Enterprise as that term is defined in the Heartland Side Letter and Framework. Except as specifically admitted herein, Company Defendants deny the allegations in paragraph 75 of the Complaint. 76. Company Defendants are without sufficient knowledge or information to form a

belief as to the truth or falsity of the allegations in paragraph 76 of the Complaint and therefore deny the m. 77.
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Company Defendants deny the allegations in paragraph 77 of the Complaint. 15

78.

Company Defendants deny each and every allegation in Plaintiffs Complaint that

is not specifically admitted herein. AFFIRMATIVE D EFENSES 1. 2. Plaintiffs have failed to state a claim upon which relief can be granted. Plaintiffs claims are barred because Plaintiffs do not have a private cause of

action under 29 U.S.C. 186. 3. Plaintiffs claims are barred because Plaintiffs lack standing to pursue the claims

in this lawsuit and therefore the Court is without subject matter jurisdiction. 4. 5. Plaintiffs claims are barred by the applicable statute of limitations. Plaintiffs claims, as pled in the Complaint, are barred because they are subject to

the primary jurisdiction of the National Labor Relations Board. 6. Plaintiffs claims are barred because Plaintiffs failed to fulfill administrative

prerequisites to bringing suit. 7. Company Defendants reserve the right to assert additional defenses as they

become known through the course of discovery or otherwise.

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WHEREFORE, having fully answered the allegations contained in Plaintiffs Complaint, Company Defendants respectfully request that the Complaint be dismissed in its entirety, that Company Defendants be awarded their costs and attorneys fees incur red in defending against this lawsuit, and for such other and further relief as this Court deems just, equitable and appropriate. Respectfully submitted,

/ s / Jeffrey B. Keiper JEFFREY B. K EIPER (0063133) JAMES M. STONE (0034691) MICHAEL L. SNYDER (0040990) MCDONALD HOPKINS CO., L.P.A. 2100 BANK ONE CENTER 600 SUPERIOR AVENUE, EAST CLEVELAND, OHIO 44114-2653 TELEPHONE: (216) 348-5400 FACSIMILE : (216) 348-5474 E-Mail: jkeiper@mcdonaldhopkins.com jstone@mcdonaldhopkins.com msnyder@mcdonaldhopkins.com ATTORNEYS FOR DEFENDANTS HEARTLAND INDUSTRIAL PARTNERS, LLP COLLINS & AIKMAN CORPORATION COLLINS & AIKMAN PRODUCTS CO. COLLINS & AIKMAN ACCESSORY MATS. INC.

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CERTIFICATE O F S ERVICE I hereby certify that on this 27th day of January 2004, a true and accurate copy of the forego ing COMPANY D EFENDANTS ANSWER AND AFFIRMATIVE D EFENSES TO PLAINTIFFS COMPLAINT was filed electronically with the United States District Court for the Northern District of Ohio, Eastern Division. Notice of this filing will be sent to all parties by operation of the Courts electronic filing system.

/ s / Jeffrey B. Keiper JEFFREY B. K EIPER (0063133) ONE OF THE ATTORNEYS FOR DEFENDANTS HEARTLAND INDUSTRIAL PARTNERS, LLP. COLLINS & AIKMAN CORPORATION COLLINS & AIKMAN PRODUCTS CO. COLLINS & AIKMAN ACCESSORY MATS. INC.

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