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 SEVERANCE BENEFITS IN CONNECTION WITH THE DEBTORS PLANNED REDUCTION-IN-FORCE 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 order authorizing severance benefits in connection with the Debtors planned reduction-in-force (the Force Reduction Motion),2 respectfully state as follows:
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 Ex Parte Motion have the meanings assigned in the Force Reduction Motion.

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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 (the Local Rules). Background 4. On May 17, 2005 (the Petition Date), the Debtors filed their voluntary

petitions for relief 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 (the Committee). 6. Contemporaneously with the filing of this Ex Parte Motion, the Debtors

filed the Force Reduction Motion seeking Court authority to pay severance benefits to the Debtors employees affected by the proposed reduction in force at the Debtors corporate headquarters. The Debtors believe that the relief requested in the Force Reduction Motion will

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provide the Debtors with substantial long-term cost savings that benefit their estates, creditors and parties in interest. 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 Force Reduction Motion to October 11, 2006 at 4:00 p.m. prevailing Eastern Time and schedule an expedited hearing to be conducted on the omnibus hearing already scheduled for October 12, 2006 at 2:00 p.m. prevailing Eastern Time. 8. Notably, neither the Committee nor the agent for the Debtors senior,

secured prepetition lenders object to the relief requested herein. Basis for Relief 9. As set forth in more detail in the Force Reduction Motion, in an effort to

rationalize and better manage their cost-base across all of their operations, the Debtors have determined to reduce corporate overhead through headcount attrition. The Debtors plan to reduce a certain number of their corporate employees will provide the Debtors with millions of dollars worth of cost-savings. The Debtors are aware that such reduction in force may

discourage other employees from remaining with the Debtors to complete the Debtors restructuring process, and, therefore, the Debtors have proposed to provide the Severance Benefits to the employees affected by such reduction in force. 10. The Debtors believe that, while the Severance Benefits may impose

certain short-term costs, these costs are outweighed by the significant cost-savings the Debtors will experience as result of the reduction in their corporate force and the benefit of maintaining employee morale. Accordingly, the Debtors are requesting an expedited notice period and

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hearing to immediately obtain the benefits provided to the Debtors by the reduction in their corporate force, which will enable the Debtors to maximize value for their estates and creditors. 11. Moreover, the Debtors wish to stress to the Court that they do not file this

Ex Parte Motion lightly, and the Debtors recognize and appreciate that any time a request for expedited notice is filed, it strains the Court and its processes. The Debtors, however, would respectfully request the Courts cooperation on this and related matters at this critical time as they attempt to meet milestones in the reorganization process and bring these cases to closure. 12. For the reasons set forth above and in the Force Reduction Motion, good

and sufficient cause exists to consider the Force Reduction Motion on an expedited basis. 13. 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 Force Reduction Motion.

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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 Force Reduction Motion to October 11, 2006 at 4:00 p.m. prevailing Eastern Time, (b) scheduling an expedited hearing on the Force Reduction Motion for October 12, 2006 at 2:00 p.m. prevailing Eastern Time and (c) granting such other and further relief as this Court deems just and proper. Dated: October 6, 2006 KIRKLAND & ELLIS LLP /s/ Ray C. Schrock 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

K&E 11404913.4

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 SEVERANCE BENEFITS IN CONNECTION WITH THE DEBTORS PLANNED REDUCTION-IN-FORCE Upon the ex parte motion for order shortening notice period and scheduling an expedited hearing (the Ex Parte Motion) on the Debtors motion for order authorizing severance benefits in connection with the Debtors planned reduction-in-force (the Force Reduction Motion);2 it appearing that the Court has jurisdiction over this 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
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 shall have the meanings assigned in the Force Reduction Motion.

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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; it appearing that 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 Force Reduction Motion will be conducted before the

Honorable Steven W. Rhodes on October 12, 2006 at 2:00 p.m. prevailing Eastern Time, or as soon thereafter as counsel may be heard, in the United States Bankruptcy Court, 211 W. Fort Street, Detroit, Michigan 48226. 3. The objection deadline for the relief requested by the Debtors in the

Force Reduction Motion shall be October 11, 2006 at 4:00 p.m. prevailing Eastern Time. 4. The Debtors shall immediately serve a copy of this Order and the

Force Reduction Motion upon the Core Group and the 2002 List.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. 7. The Court retains jurisdiction with respect to all matters arising from or

related to the implementation of this Order.

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 filed on June 9, 2005 [Docket No. 294].

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