UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION - DETROIT IN THE MATTER OF: COLLINS &

AIKMAN CORPORATION, et al. Debtors. _______________________________________/ Bankruptcy No. 05-55927-SWR (Jointly Administered) Honorable STEVEN W. RHODES Chapter 11

EMPIRE ELECTRONICS. INC.S OBJECTION TO NOTICE OF RECLAMATION CLAIMS THE DEBTORS DEEM TO BE VALID NOW COMES, Empire Electronics, Inc., by and through counsel, KILPATRICK & ASSOCIATES, P.C., and for its Objection to Notice of Reclamation Claims the Debtors Deem to be Valid (Notice), states as follows: 1. On or about May 17, 2005, the Debtors filed Voluntary Petitions for relief under

Chapter 11 of the United States Bankruptcy Code (Petition Date). 2. Empire Electronics, Inc. (Empire) is a Creditor of the Debtors, and is engaged

in the sale of goods to the Debtors, including the sale of harnesses used in Debtors production of Rear Object Sensors on the Rear Fascia on DaimlerChrysler RS Platforms. 3. By letter dated May 20, 2005, addressed to Debtors location in Troy, Michigan,

Empire made a demand for reclamation of goods delivered to Collins & Aikman by Empire (Reclamation Demand). A copy of the letter was also sent to Debtors counsel in New York. 4. The Debtors claim that the Reclamation Demand by Empire in the amount of

$25,442.20 was not made within the appropriate time period. 5. The Reclamation Demand was sent via DHL Overnight Service, parcel no.

26346411840 and received by the Debtor on May 24, 2005. See DHL Track results detail attached as Exhibit A. 6. Since the Reclamation Demand was received by the Debtors within 7 days of the

Petition Date, it is a valid claim and the reduction should be denied.

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The Debtors have not provided any evidence that the goods subject to the

Reclamation Demand were, in fact, consumed prior to receiving the Reclamation Demand nor have they identified the invoices of the Reclamation Demand to which the reduction corresponds. 8. Accordingly, the Debtors claim of invalidity of the Reclamation Demand by

Empire should be denied. WHEREFORE, Empire Electronics, Inc. respectfully requests that this Court enter an order striking Debtors Notice insofar as it invalidates any amount of the reclamation claim of Empire Electronics, Inc. and grant such further relief as the Court deems just and equitable given the facts of the case. Respectfully Submitted, KILPATRICK & ASSOCIATES, P.C.

By:

/s/Leonora K. Baughman RICHARDO I. KILPATRICK (P35275) LEONORA K. BAUGHMAN (P33534) Attorneys for Empire Electronics, Inc. 903 N. Opdyke Road, Suite C Auburn Hills, Michigan 48326 (248) 377-0700

Dated: September 27, 2005