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 ENTRY OF AN ORDER ADJOURNING THE HEARING ON CONFIRMATION OF THE DEBTORS CHAPTER 11 PLAN The above-captioned debtors (collectively, the Debtors) hereby move the Court (the Ex Parte Motion) for the entry of an order adjourning the hearing on confirmation of the Debtors chapter 11 plan to on or about July 12, 2007. In support of this Ex Parte Motion, the Debtors respectfully state as follows:

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. 05-55991; 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. 05-55964; 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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Introduction A hearing on confirmation of the Debtors chapter 11 plan is currently scheduled before this Court for June 5, 2007. The Debtors have made substantial progress towards satisfying all conditions to confirmation and intend to provide the Court with a status of such progress at the June 5, 2007 hearing. In particular, the Debtors have (a) finalized, and the Court has recently approved, an agreement with the Pension Benefit Guaranty Corporation terminating the Debtors pension plan and settling related claims, (b) reached an agreement in principle with the United Auto Workers (UAW) regarding retiree benefits as required by the plan, (c) finalized and will move forward to approve the sale of substantially all of the Debtors assets involved in their Carpet & Acoustics business segment at the June 5, 2007 hearing and (d) resolved certain formal and informal objections to confirmation of their chapter 11 plan. Nevertheless, the Debtors and the agent to the Debtors prepetition senior, secured lenders (the Prepetition Agent) have agreed that it is in the best interests of all parties to request a short adjournment of the confirmation hearing in accordance with the Solicitation Procedures Order (as defined below). The Debtors and the Prepetition Agent believe that a short adjournment will allow the Debtors to, among other things, (a) finalize an agreement or agreements for the disposition of most of their plastics business, (b) move for approval of a global settlement with General Electric Capital Corporation (GECC), which settlement is integral to the plan and various asset sales, (c) move for approval of a stipulation with the UAW regarding retiree benefits and (d) finalize certain other settlements that the Debtors currently are negotiating to resolve issues necessary to conclude these cases. 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

2. 3.

Venue is proper pursuant to 28 U.S.C. 1408 and 1409. The statutory bases for the relief requested herein are Rule 9006 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. On January 24, 2007, the Debtors filed the First Amended Joint Plan of Collins & On

Aikman Corporation and Its Debtor Subsidiaries [Docket No. 3976] (the Plan).

January 26, 2007, the Court entered an order approving the Debtors amended disclosure statement and solicitation procedures related to the Plan Solicitation Procedures Order). 5. The deadline for creditors to vote on the Plan and to file objections to [Docket No. 3988] (the

confirmation of the Plan was May 7, 2007. This Court has scheduled a hearing on confirmation of the Plan for June 5, 2007 (the Confirmation Hearing). 6. Pursuant to paragraph 8 of the Solicitation Procedures Order, the Debtors may

adjourn the Confirmation Hearing without further notice; provided that if the Debtors adjourn the Confirmation Hearing after the deadline to object to the Plan, the Debtors shall provide written notice of such adjournment to the Core Group, the 2002 List and any party that has objected to confirmation of the Plan.2

Capitalized terms used in this paragraph 6 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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Relief Requested 7. The Debtors respectfully request that, pursuant to Bankruptcy Rule 9006(b),

Local Rule 9006-1(b) and the Solicitation Procedures Order, the Court enter an order adjourning the Confirmation Hearing until on or about July 12, 2007. Basis for Relief 8. Since the entry of the Solicitation Procedures Order, the Debtors have worked

diligently to satisfy all of the conditions to confirmation of the Plan. Despite the Debtors best efforts, the Debtors will not be able to satisfy all of the conditions by June 5, 2007. In particular, one of the conditions to confirmation of the Plan is the resolution of claims related to retiree benefits. The Debtors are pleased to report that they have reached an agreement in principle with the UAW regarding the resolution of such claims. The Debtors intend to finalize and submit the resolution for Court approval in the next few days; however, approval of such resolution will be scheduled to occur after June 5, 2007. 9. Another condition to confirmation is the consummation of the sale of

substantially all of the Debtors assets involved in their Carpet & Acoustics business segment (the Carpet & Acoustics Assets). The Debtors have worked extensively with their major constituents to market and sell the Carpet & Acoustics Assets and are prepared to proceed with the approval of the sale of the Carpet & Acoustics Assets at the hearing scheduled for June 5, 2007. The Debtors are confident that the Court will find that approval of the sale of the Carpet & Acoustics Assets at the June 5, 2007 hearing is in the best interests of the Debtors estates; however, the Debtors will require some additional time thereafter to satisfy any requirements under the asset purchase agreement to consummate the sale. 10. Furthermore, the Debtors, in consultation with the Prepetition Agent, continue to

work diligently with GECC (one of the Debtors largest creditors in these cases) to finalize a 4
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global resolution among the parties regarding the Debtors obligations with a face amount of approximately $76 million related to the Debtors facility in Hermosillo, Mexico and the Debtors obligations with a face amount of approximately $45 million related to equipment that is the subject of various financing agreements. Although not an explicit condition to

confirmation of the Plan, a resolution of these disputes is integral to the Plan and various asset sales and will relieve the Debtors of the heavy encumbrance that such disputes have placed and would continue to place on the Debtors estates and their creditors. Based upon the most recent conversation between the parties, the Debtors are confident a motion to approve a settlement with GECC will be filed imminently but would not be heard until after June 5, 2007. 11. Accordingly, the Debtors and the Prepetition Agent agree that it is in the best

interests of the Debtors estates and their creditors to adjourn the Confirmation Hearing until on or about July 12, 2007. Pursuant to the Solicitation Procedures Order, the Debtors will provide notice of such adjournment to the Core Group, the 2002 List and any party that has objected to confirmation of the Plan.3 12. For the reasons set forth above, good and sufficient cause exists to adjourn the

Confirmation Hearing until on or about July 12, 2007.

Capitalized terms used in this paragraph 11 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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WHEREFORE, the Debtors respectfully request the entry of an order, substantially in the form attached hereto as Exhibit A, (a) adjourning the Confirmation Hearing until on or about July 12, 2007 and (b) granting such other and further relief as is just and proper. Dated: May 31, 2007 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

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 ADJOURNING THE HEARING ON CONFIRMATION OF THE DEBTORS CHAPTER 11 PLAN Upon the ex parte motion for the entry of an order adjourning the hearing on confirmation of the Debtors chapter 11 plan (the Ex Parte 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 appearing that venue of this proceeding and the Ex Parte Motion in this District is proper pursuant to 28 U.S.C. 1408

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. 05-55991; 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. 05-55964; 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 Ex Parte Motion.

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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. The Confirmation Hearing is adjourned until July 12, 2007 at __:__ __.m.

prevailing Eastern Time, which hearing may be continued from time to time by the Court or the Debtors; provided that the Debtors shall provide written notice of such adjournment to the Core Group, the 2002 List and any party that has objected to confirmation of the Plan.3 3. The Debtors shall immediately serve a copy of this Order upon the

Core Group, the 2002 List and any party that has objected to confirmation of the Plan.4 4. The Debtors are authorized and empowered to take all actions necessary to

implement the relief granted in this Order. 5. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 6. 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 2 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]. Capitalized terms used in this paragraph 3 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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