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 (A) EXTENDING THE DEADLINE TO VOTE ON OR OBJECT TO THE DEBTORS CHAPTER 11 PLAN AND (B) ADJOURNING THE HEARING ON CONFIRMATION OF SUCH PLAN The above-captioned debtors (collectively, the Debtors) hereby move the Court (the Ex Parte Motion) for entry of an order (a) extending the deadline to vote on or object to the Debtors chapter 11 plan and (b) adjourning the hearing on confirmation of such plan. 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).

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. 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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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 May 17, 2005 (the Petition Date), the Debtors filed their voluntary petitions

for relief under chapter 11 of 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 the official committee of

unsecured creditors pursuant to section 1102 of the Bankruptcy Code (the Committee). 6. On January 11, 2007, the Court approved on a final basis that certain

Customer Agreement (the Customer Agreement) by and between the Debtors, the agents for the Debtors senior, secured prepetition and postpetition lenders and certain of the Debtors principal customers (the Customers) [Docket No. 3890]. The Customer Agreement, among other things, provides for a framework to facilitate the orderly sale of a majority of the Debtors businesses. 7. 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 [Docket No. 3988] (the Solicitation Procedures Order). 2
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8.

The Debtors have commenced the solicitation process in connection with the

Plan. Pursuant to the Solicitation Procedures Order, the deadline for creditors to vote on the Plan is April 7, 2007 (the Voting Deadline) Additionally, this Court has scheduled a hearing on confirmation of the Plan for April 19, 2007 (the Confirmation Hearing). 9. Under paragraph 7 of the Solicitation Procedures Order, the Debtors or the Court

may extend the deadline to vote on the Plan (the Voting Deadline) to a date that is no later than five days before the Confirmation Hearing with notice to all creditors entitled to vote on the Plan. Additionally, pursuant to paragraph 8 of the Solicitation Procedures Order, the Debtors or the Court may adjourn the Confirmation Hearing without further notice; provided, 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 objecting party.2 Relief Requested 10. 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 (a) extending the Voting Deadline and the deadline to object to the Plans confirmation until May 7, 2007 and (b) adjourning the Confirmation Hearing until on or about May 24, 2007. Basis for Relief 11. As the Debtors have disclosed to the Court and publicly, to maximize the value of

the Debtors estates and save jobs, the Debtors are pursuing a cooperative sale process, which the Debtors expect will culminate with the confirmation of the Plan. Since the entry of the

Capitalized terms used in this paragraph 8 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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Solicitation Procedures Order, the Debtors have worked diligently to satisfy all of the conditions to confirmation of the Plan. In particular, the Debtors have worked extensively with their major constituents to market and sell the Debtors assets, in accordance with the deadlines set forth in the Plan and the Customer Agreement, and settle several major outstanding creditor disputes. 12. The Debtors believe that they will require a short extension to satisfy the Therefore, after consulting with the Committees

conditions to confirmation of the Plan.

advisors and the agent for the Debtors prepetition senior, secured lenders and as authorized in the Solicitation Procedures Order, the Debtors have determined that it is in the best interests of the Debtors estates and their creditors file the Ex Parte Motion to (a) extend the Voting Deadline and the Plan objection deadline until May 7, 2007 and (b) adjourn the Confirmation Hearing until on or about May 24, 2007. 13. For the reasons set forth above, good and sufficient cause exists to (a) extend the

Voting Deadline and (b) adjourn the Confirmation Hearing.

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WHEREFORE, the Debtors respectfully request the entry of an order, substantially in the form attached hereto as Exhibit A, (a) extending the Voting Deadline and the Plan confirmation objection deadline until May 7, 2007, (b) adjourning the Confirmation Hearing until on or about May 24, 2007 and (c) granting such other and further relief as this Court deems appropriate. Dated: March 28, 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

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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 (A) EXTENDING THE DEADLINE TO VOTE ON AND OBJECT TO THE DEBTORS CHAPTER 11 PLAN AND (B) ADJOURNING THE HEARING ON CONFIRMATION OF SUCH PLAN Upon the ex parte motion for entry of an order (a) extending the deadline to vote on the Debtors chapter 11 plan and (b) adjourning the hearing on confirmation of such 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
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. 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. Except as otherwise set forth herein, capitalized terms used but not otherwise defined in this Order have the meanings set forth in the Ex Parte Motion.

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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. The Voting Deadline on the Plan and the Plan confirmation objection

deadline shall be extended until May 7, 2007 at 5:00 p.m., prevailing Pacific Time; provided that the Debtors may extend such Voting Deadline, if necessary, without further order of the Court, to a date no later than five days before the Confirmation Hearing with notice to all creditors entitled to vote on the Plan. 3. The Confirmation Hearing is adjourned until May __, 2007, which hearing

may be continued from time to time by the Court or the Debtors without further notice other than adjournments announced in open court; 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 objecting party. 4. The Debtors shall immediately (a) serve a copy of this Order upon the

Core Group, the 2002 List3 and (b) shall notify all creditors entitled to vote on the Plan as required in the Solicitation Procedures Order. 5. The Debtors are authorized and empowered to take all actions necessary to

implement the relief granted in 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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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.

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