UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION IN RE: COLLINS & AIKMAN CORP. et al.

Debtors. Tax Id. No. 13-3489233 / Hon. Steven W. Rhodes Chapter 11 Case No. 05-55927 Jointly Administered

FEDERAL-MOGUL CORPORATIONS OBJECTION TO DEBTORS MOTION FOR ORDER DEEMING RECLAMATION CLAIMS TO BE GENERAL UNSECURED CLAIMS AGAINST THE DEBTORS Federal-Mogul Corporation (Federal-Mogul), a creditor of the Debtors, states: BACKGROUND 1. On June 9, 2005, the Court entered an Order (the Reclamation Procedures Order)

granting the Debtors Emergency Motion for Order (a) Establishing Procedures for Treatment of Valid Reclamation Claims and (b) Prohibiting Third Parties from Interfering with Delivery of the Debtors Goods. 2. Federal-Mogul timely served a reclamation demand for the return of goods valued at

$155,858.56. 3. claim. 4. After further negotiations, discussions and reconciliation, Federal-Mogul and the The Debtors subsequently filed a Reclamation Notice contesting the amount of the

Debtors agreed that Federal-Mogul had a valid reclamation demand in the amount of $23,286.46. 5. The Debtors have now filed a motion attempting to recharacterize all reclamation

claims as general unsecured claims (the Reclamation Disallowance Motion). For the reasons stated below, Federal-Mogul objects.

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OBJECTION 6. Other creditors, including Jason, Inc. and Pioneer Automotive Technologies, Inc.

(Docket No. 4056) and Meridian Technologies, Inc. (Docket No. 4038) have already objected to the Debtors Reclamation Disallowance Motion. 7. In the interest of avoiding needless repetition, the Objecting Creditors reiterate the

objections and statements of law already stated in the objections of Jason, Inc. and Pioneer Automotive Technologies, Inc. and Meridian Technologies, Inc. 8. Additionally, to the extent that Federal-Moguls rights to reclamation may be subject

to the rights of the Debtors Prepetition Lenders (which Federal-Mogul contests), the Debtors have no standing to raise the rights of these third parties. Nothing in the Bankruptcy Code or otherwise entitles the debtors in chapter 11 proceedings to raise the rights of third party lien claimants to avoid their obligations to reclamation creditors. 11 U.S.C. 546(c) (The rights and powers of a trustee under sections 544(a), 545, 547, and 549 of this title are subject to any statutory or common law right of a seller of goods . . .). If another party has superior rights, only that party may assert those rights. CONCLUSION WHEREFORE, for all the reasons stated above, and in the objections of Jason, Inc. and Pioneer Automotive Technologies, Inc. and Meridian Technologies, Inc., Federal-Mogul requests that this Honorable Court deny the Debtors Reclamation Disallowance Motion. Respectfully Submitted, SCHAFER AND WEINER, PLLC By: /s / Ryan D. Heilman RYAN HEILMAN (P63952) Counsel for Federal-Mogul Corporation 40950 Woodward Ave., Ste. 100 Bloomfield Hills, MI 48304 (248) 540-3340 rheilman@schaferandweiner.com 2

Dated: February 8, 2007

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION IN RE: COLLINS & AIKMAN CORP. et al. Debtors. Tax Id. No. 13-3489233 / Hon. Steven W. Rhodes Chapter 11 Case No. 05-55927 Jointly Administered

CERTIFICATE OF SERVICE I hereby certify that on February 8, 2007 I served the following: Joinder of Federal-Mogul Corporation to on the following parties via E-Mail: Richard M. Cieri, Esq. David L. Eaton, Esq. Ray C. Schrock, Esq. Marc J. Carmel, Esq. Joseph M. Fischer, Esq. rcieri@kirkland.com deaton@kirkland.com rschrock@kirkland.com mcarmel@kirkland.com jfischer@carsonfischer.com

/s/ Melissa Allport, Legal Assistant to RYAN D. HEILMAN (P63952) Schafer and Weiner, PLLC 40950 Woodward Ave., Ste. 100 Bloomfield Hills, MI 48304 Telephone: (248) 540-3340 Facsimile: (248) 642-2127 rheilman@schaferandweiner.com COUNSEL FOR FEDERAL-MOGUL CORPORATION

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