UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

) ) COLLINS & AIKMAN CORPORATION, et al., ) a Delaware corporation, ) ) Debtor. ) )

In re:

Chapter 11 Case No. 05-55927-SWR Hon. Steven W. Rhodes

LIMITED OBJECTION OF HALLMARK TOOLS TO GENERAL MOTORS CORPORATIONS AMENDED MOTION FOR CONTINGENT RELIEF FROM AUTOMATIC STAY TO OBTAIN POSSESSION OF TOOLING

Hallmark Tools, a division of Hallmark Technologies, Inc. (Hallmark), for its Limited Objection to General Motors Corporations Amended Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling (the Amended Motion) states: 1. On September 8, 2006, General Motors Corporation (GM) filed the

Amended Motion. 2. Contained in the Amended Motion are representations by GM that: i.) GM owns the Relevant Tooling; ii.) the Debtor has no equity in the Relevant Tooling; iii.) GM has paid the Debtor for the Relevant Tooling. 3. Hallmark has fabricated certain molds (Hallmark Molds) that it is in the

process of fabricating and performing engineering changes for the Debtor for the GMX 384 Saturn Aura Instrument Panel. In addition, Hallmark also claims a lien on the Hallmark Molds pursuant to a statute commonly known as the Michigan Mold Lien Act,

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MCL 445.611 et seq. (the Act), that it fabricated for the Debtor as well as performed engineering changes that are used to manufacture parts for the GMX 384 Instrument Panel for the Saturn Aura and believes that some or all of the Hallmark Molds may be included in the tooling referenced in the Amended Motion of which GM proposes to take possession from the Debtor. 4. Pursuant to the Act, prior to shipping the Hallmark Molds to the Debtor,

Hallmark properly affixed its name and address on the Molds. 5. Hallmark filed UCC-1 financing statements relative to the Hallmark Molds

as required by the Act. 6. Hallmark has an ownership interest in the Hallmark Molds; alternatively, it

has a statutory lien against the Hallmark Molds. 7. The Amended Motion fails to recognize Hallmarks ownership

interest/statutory lien on the Hallmark Molds and to provide for payment to satisfy Hallmarks lien on the Hallmark Molds. 8. According to GMs supporting documentation attached to the Amended

Motion, Hallmark believes that GM may have paid the Debtor for the Hallmark Molds, yet Hallmark has not been paid by the Debtor for the Hallmark Molds. Representations have been made by the Debtor to Hallmark that GM has not paid for the Hallmark Molds 9. Hallmark objects to GMs requested relief to the extent that Hallmarks

ownership interest/statutory lien on the Hallmark Molds is not recognized and/or satisfied. 10. Hallmark does not object to the proposed relief requested by GM relative

to molds and tools other than the Hallmark Molds.

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THEREFORE, Hallmark respectfully requests that the Court deny General Motors Corporations Amended Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling to the extent that it fails to recognize and satisfy Hallmarks ownership interest/statutory lien on the Hallmark Molds and grant such further and additional relief as deemed just and proper. Respectfully submitted,

________/s/ Dennis W. Loughlin____ Lynn Brimer (P43291) Dennis W. Loughlin (P57084) Strobl & Sharp, P.C. 300 E. Long Lake Road, Suite 200 Bloomfield Hills, MI 48304-2376 (248) 540-2300; fax (248) 645-2690 Attorneys for Defendants Dated: October 6, 2006

ECF Certificate of Service The undersigned certifies that a copy of the foregoing pleading was served upon each attorney or party of record herein by electronic means or first class U.S. mail on October 6, 2006. By: /s/Dennis W. Loughlin Dennis W. Loughlin (P57084)

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