UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MICHIGAN In Re: Case No.

05-55927 (SWR) (Jointly Administered) COLLINS & AIKMAN CORPORATION, et al. Debtor. / OBJECTION TO CONFIRMATION OF THE DEBTORS PLAN, AS AMENDED NOW COMES the Inmet Division of Multimatic (Multimatic), and states: 1. Multimatic is a creditor of C & A Canada. Upon information and belief, Chapter 11 Hon. Steven W. Rhodes

C & A Canada is wholly owned by one of the chapter 11 debtors before this Court. Multimatic has also been scheduled as a general unsecured creditor as to one of the chapter 11 debtors. 2. This Court should not confirm the Debtors plan, as amended for the

following reasons: a. The plan provides for a release and satisfaction of claims. Under the

bankruptcy code, claimants may be enjoined from asserting their claims against the debtor under 11 U.S.C. 524, however, those claims are not released or satisfied. This is important to the extent that a claimant such as Multimatic has claims which are owed by both a chapter 11 debtor and by C & A Canada. b. The plan appears to eliminate a partys right of offset or to assert

counterclaims. This is important as to objections to proofs of claim and as to adversary proceedings. As such, the Debtors plan does not comply with the applicable provisions of the Bankruptcy Code, and thus cannot be confirmed under 11 U.S.C. 1129(a)(1).

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c.

The plan provides for a discharge of claims against nondebtor parties,

contrary to 11 U.S.C. 524(e). The requirements for a superdischarge under 11 U.S.C. 524(g) have not been met, and thus there is no authority for the scope of the discharge provided in the Debtors plan. d. The plan unfairly discriminates between unsecured creditors who vote for

the plan, who will get paid, and unsecured creditors who do not vote for the plan. 11 U.S.C. 1129(b). Furthermore, the Debtor is improperly creating a class of general unsecured claimants who vote for the plan, possibly in order to artificially create an impaired accepting class to satisfy 11 U.S.C. 1129(a)(10). Additionally, it is improper to separately classify a class of accepting general unsecured claimants, from general unsecured claimants who do not vote for a plan, under 11 U.S.C. 1122-1124. Even if it is true that general unsecured creditors would not get paid in a chapter 7 liquidation, this does not justify this artificial classification and disparate treatment. The best interests of creditors requirement of 11 U.S.C. 1129(a)(7) is distinct from the requirement that the plan not unfairly discriminate under 11 U.S.C. 1129(b), and the requirement that the plan comply with the applicable provisions of the Bankruptcy Code under 11 U.S.C. 1129(a)(1), which incorporates the classification requirements of 11 U.S.C. 11221124. Moreover, Debtors plan impermissibly creates a class of accepting general unsecured creditors in violation of 11 U.S.C. 1123(a)(4), which requires that all claimants within a class receive equal treatment, absent an agreement to the contrary. Debtors classification scheme , if approved, would allow an end-run around this statutory requirement.

e.

The plan purports to discharge postconfirmation claims under Article XII

C (currently existing or hereafter arising), which is inconsistent with a chapter 11 discharge which only can discharge preconfirmation claims. Accordingly, the plan does not comply with applicable provisions of the Bankruptcy Code, and is proposed by means forbidden by the law. 3. In light of, inter alia, the unavailability of certain exhibits to the Plan,

Multimatic reserves its ability to supplement its objections. WHEREFORE, this Court should not confirm the Debtors chapter 11 plan as currently drafted, and should grant Multimatic such further relief as this Court deems just.

Respectfully Submitted, KEMP, KLEIN, UMPHREY, ENDELMAN & MAY, P.C. _/s/ Robert Bassel Robert N. Bassel (P48420) Attorney for Multimatic P. O. Box 4300 Troy, MI 48099-4300 (248) 528-1111 Dated: 5.7.07

UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MICHIGAN In Re: Case No. 05-55927 (SWR) (Jointly Administered) COLLINS & AIKMAN CORPORATION, et al. Debtor. / PROOF OF SERVICE The undersigned states that on 5.7.07, he filed the above document through the ECF system which is designed to serve all counsel of record for all parties in interest. A copy of the most recent listing of counsel of record is voluminous, and available at the Courts ECF website. Chapter 11 Hon. Steven W. Rhodes

Respectfully Submitted, KEMP, KLEIN, UMPHREY, ENDELMAN & MAY, P.C. _/s/ Robert Bassel Robert N. Bassel (P48420) Attorney for Multimatic P. O. Box 4300 Troy, MI 48099-4300 (248) 528-1111 Dated: 5.7.07