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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 Honorable STEVEN W. RHODES Chapter 11

LIMITED OBJECTION TO DEBTORS MOTION FOR ORDER AUTHORIZING ENTRY INTO AGREEMENT WITH TOYOTA MOTOR MANUFACTURING NORTH AMERICA INC. PROVIDING FOR IMMEDIATE PRICE RELIEF AND OTHER RELATED BENEFITS NOW COMES Creditor, Toyota Motor Credit Corporation, (TMCC) by and through its counsel, KILPATRICK & ASSOCIATES, P.C., and for its Limited Objection To Debtors Motion For Order Authorizing Entry Into Agreement With Toyota Motor Manufacturing North America Inc. Providing For Immediate Price Relief And Other Related Benefits (Debtors Motion), states as follows: 1. On or about May 17, 2005, the Debtors filed a Voluntary Petition under Chapter 11, Title

11 of the U.S. Bankruptcy Code. 2. On the date of the filing of this case, the Debtors were indebted to TMCC and in

possession of 166 units of equipment (Equipment) as to which TMCC holds an ownership interest. 3. The Equipment was leased pursuant to a Master Lease Agreement dated November 1,

1999 and various Supplements for specific items of equipment dated thereafter (Lease Agreement). 4. Pursuant to the Stipulated Order Providing for Adequate Protection Payments to Toyota

Motor Credit Corporation dated August 15, 2005 (Adequate Protection Order), the Debtors were required to make monthly adequate protection payments to TMCC for the Equipment. 5. The Debtors are currently past due on the Adequate Protection Order in the amount of

Forty Two Thousand and 00/100 Dollars ($42,000.00) resulting from the Debtors failure to pay the September, 2005 payments under the Lease Agreement.

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On September 14. 2005, TMCC filed its Motion to Compel Assumption or Rejection of

the Lease Agreement for the Equipment between the Debtors and TMCC (Docket #1166). The hearing on TMCCs Motion is currently scheduled for October 14, 2005. 7. The Debtors Motion states that the Debtors have reached an agreement with Toyota

Motor Manufacturing North America Inc. and its affiliates, thereafter called the Customer. 8. Toyota Motor Manufacturing North America Inc. and TMCC are each subsidiaries of

Toyota Motor Corporation according to the Form 20-F filed by Toyota Motor Corporation with the Securities and Exchange Commission on June 24, 2005. 9. TMCC files this Limited Objection out of an abundance of caution since it could be

deemed to be an affiliate and therefore, subject to the terms of the Agreement between the Debtors and Toyota Motor Manufacturing North America Inc. 10. TMCC is not a customer of the Debtors and should be specifically excluded from the

definition of Customer in any order approving the relief requested in Debtors Motion. 11. TMCC does not consent to the use, sale or lease of the Equipment outside of the use by

the Debtors in its production operation and any contrary use, sale or lease should be prohibited without advance notice to TMCC and Court permission. WHEREFORE, Toyota Motor Credit Corporation prays this Court issue an Order which specifically limits the definition of Customer to not include Toyota Motor Credit Corporation and grant whatever further and other relief this Court deems just and proper. Respectfully submitted; KILPATRICK & ASSOCIATES, P.C.

/s/Leonora K. Baughman RICHARDO I. KILPATRICK (P35275) LEONORA K. BAUGHMAN (P33534) Attorneys for Creditor, Toyota Motor Credit Corporation 903 North Opdyke Road, Suite C Auburn Hills, MI 48326 (248) 377 - 0700 Dated: September 28, 2005

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