UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION COLLINS & AIKMAN CORPORATION, et al., Debtor.

______________________________________/ RCO ENGINEERING, INC.S RESPONSE TO COLLINS &AIKMAN POST-CONSUMMATION TRUSTS SIXTY-FIRST OMNIBUS OBJECTION TO CLAIMS (INSUFFICIENT BOOKS AND RECORDS) RCO Engineering, Inc. (RCO), by its counsel, Allard & Fish, P.C., hereby submits this Response to Collins & Aikman Post-Consummation Trusts Sixty-First Omnibus Objection to Claims (Insufficient Books and Records) (the Objection). In support of this Response, RCO states as follows: 1. On May 17, 2005 (the Petition Date), the Debtors filed a voluntary petition for Case No. 05-55927-SWR Chapter 11 Judge Steven W. Rhodes

relief under Chapter 11 of Title 11 of the United States Bankruptcy Code (the Code). 2. The Debtors First Amended Joint Plan (the Plan) was confirmed on July 18,

2007. The Plans effective date is October 12, 2007. 3. On July 15, 2008, the Collins & Aikman Post-Consummation Trust filed its

Objection, seeking to reduce RCOs claim on the basis the Debtors books and records do not support RCOs claims. 4. RCO and the Debtors have already resolved RCOs claim by virtue of a

settlement agreement and the Courts corresponding Order Granting Debtors Motion to Approve Settlement and Compromise of Claims with Respect to RCO Engineering, Inc. in Adversary Proceeding No. 07-05687, docket no. 9290.

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WHEREFORE, RCO respectfully requests that the Court overrule the Collins & Aikman Post-Consummation Trusts Sixty-First Omnibus Objection to Claims (Insufficient Books and Records) and that RCOs claim be allowed in accordance with the Courts Order Granting Debtors Motion to Approve Settlement and Compromise of Claims with Respect to RCO Engineering, Inc. in Adversary Proceeding No. 07-05687, docket no. 9290, and the corresponding settlement agreement. ALLARD & FISH, P.C.

/S/Timothy R. Graves Attorneys for Johns Manville Corporation 2600 Buhl Building 535 Griswold Detroit, MI 48226 (313) 961-6141 tgraves@allardfishpc.com P64622 Dated: August 11, 2008
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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION COLLINS & AIKMAN CORPORATION, et al., Debtor. ______________________________________/ CERTIFICATION OF SERVICE I, Camellia Williams, hereby certify that on August 11, 2008, I electronically filed the following: RCO Engineering, Inc.s Response to Collins & Aikman Post-Consummation Trusts Sixty-First Omnibus Objection to Claims (Insufficient Books and Records) with the Clerk of the Court using the ECF and I hereby certify that the Courts ECF system has served all registered users. Case No. 05-55927-SWR Chapter 11 Judge Steven W. Rhodes

ALLARD & FISH, P.C.

/S/ Camellia Williams 535 Griswold 2600 Buhl Building Detroit MI 48226 (313) 961-6141

Dated: August 11, 2008

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