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IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION,

et al., ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered)

Debtors.

OBJECTION OF ADVANCED COMPOSITES, INC. TO CURE AMOUNTS LISTED IN THE EXHIBITS ACCOMPANYING THE NOTICE OF SALE OF ASSETS OF DEBTORS INTERIORS PLASTICS GROUP FREE AND CLEAR OF LIENS, CLAIMS, ENCUMBRANCES AND INTERESTS

Advanced Composites, Inc., ("Advanced Composites") is a creditor and counter-party to numerous contracts with one or more of the above-captioned debtors and debtors in possession (collectively, the Debtors). In connection with the Notice of Sale of Assets of Debtors Interiors Plastics Group Free and Clear of Liens, Claims, Encumbrances and Interests accompanying exhibits (the Notice of Sale), many of those contracts were identified as Assumed Agreements, and the cure amount due to Advanced Composites under each such Assumed Agreement was listed as zero. In fact, as of the date hereof, the cure amounts due to Advanced Composites total $2,043,700.38. Advanced Composites, by its undersigned counsel, therefore submits this objection to the cure amounts set forth by the Debtors, and in support of its objection, respectfully alleges as follows: DISCUSSION 1. Advanced Composites is in the business of manufacturing and

supplying raw materials, including (among other things) polypropylene composites. Prior to the Debtors bankruptcy filings, Advanced Composites entered into contracts and purchase

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0555927070511000000000010

*9

orders with one or more of the Debtors, pursuant to which Advanced Composites provided , and continues to provide, the Debtors with product. 2. The exhibits to the Notice of Sale identify numerous of the contracts

between Advanced Composites and the Debtors as Assumed Agreements, but incorrectly state that no cure amounts are due thereunder. The books and records of Advanced

Composites show that as of the Debtors bankruptcy filings, the amounts due under the contracts total $2,043,700.38 (the Cure Amount). While the Debtors have remained

current with Advanced Composites on account of post-petition dealings to date, no payment has ever been received in connection with the pre-petition amount due, and that amount the Cure Amount -- remains outstanding. 3. Attached hereto as Exhibit A is a schedule of the contracts and

purchase orders under which the Debtors are currently indebted to Advanced Composites. The schedule indicates the amount owed by contract or purchase order, and is consistent with the proof of claim that was timely filed by Advanced Composites in these cases. (Additional detail is available to the Debtors and the proposed purchaser(s) upon request.) 4. In addition, as noted on the schedule provided, Advanced Composites

continues to provide product to the Debtors and anticipates that it will be supplying product on several of the purchase orders in the near term. Advanced Composites therefore reserves its rights to amend this objection and modify the Cure Amount, in the event that the amounts due to Advanced Composites change prior to the closing of the proposed sale. 5. Provided that the purchaser promptly pays the Cure Amount,

Advanced Composite does not object to the proposed assumption and assignment of its contracts and purchase orders to Cadence Innovation, LLC. In the event that another entity is the successful bidder at auction, Advanced Composites requests prompt receipt of evidence of the financial bona fides of that entity, and reserves its rights to object to the assumption

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and assignment if such information is not promptly provided or is not satisfactory to Advanced Composites. WHEREFORE, Advanced Composites objects to the cure amounts set forth in the exhibits to the Notice of Sale. Dated: May 11, 2007 HALPERIN BATTAGLIA RAICHT, LLP Attorneys for Advanced Composites By: /s/ Donna H. Lieberman Alan D. Halperin (AH-8432) Donna H. Lieberman (DL-3553) 555 Madison Avenue 9th Floor New York, New York 10022 Phone: (212) 765-9100 Fax: (212) 765-0964 Email: ahalperin@halperinlaw.net dlieberman@halperinlaw.net

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EXHIBIT A

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ADVANCED COMPOSITES COLLINS & AIKMAN

PO No. 14146* 14254* 59584 60376 70008 70090 70458 70647 70674 70676 70794 70800 71016* 83379 010343 033509* 108415 300050* 318270 2005036 2005039 1831-00013 1961-00051 R113677 R3088 Total Due

Amount Due 629,550.50 138,324.40 150.00 528.00 249,255.00 18,405.00 11,040.00 1,865.00 6,270.00 8,806.61 3,132.10 81,384.89 163,933.64 12,690.00 4,275.00 11,985.00 13,329.50 221,740.40 392,820.50 56,224.10 1,230.00 4,260.00 3,969.00 5,891.74 2,640.00 2,043,700.38

* Number may change, as additional product is likely to be provided by Advanced Composites

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