UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

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IN RE:

) ) COLLINS & AIKMAN CORPORATION, et al., ) ) Debtors. ) / )

Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) Honorable Steven W. Rhodes

PROTECTIVE OBJECTION OF H.S. DIE & ENGINEERING, INC. TO DEBTORS MOTION FOR THE ENTRY OF ORDERS APPROVING BIDDING PROCEDURES, SALE OF CERTAIN ASSETS OF THE DEBTORS INTERIOR PLASTICS GROUP FREE AND CLEAR OF LIENS, CLAIMS, ENCUMBRANCES AND INTERESTS AND RELATED RELIEF

H.S. Die & Engineering, Inc., on behalf of itself and any and all of its subsidiaries including, but not limited to, H.S. Die Rantoul Mold Service, L.L.C. (collectively, H.S. Die), through its counsel, Miller Johnson, for its Protective Objection
(this Objection) To Debtors Motion For The Entry Of Orders Approving Bidding Procedures, Sale Of Certain Assets Of The Debtors Interior Plastics Group Free And Clear Of Liens, Claims, Encumbrances And Interests And Related Relief (the Motion), states as follows:

1.

On May 17, 2005 (the Petition Date), the Debtors filed their The Debtors

voluntary petitions for relief under chapter 11 of the Bankruptcy Code.

continue to operate their businesses and manage 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, this Court entered an order jointly administering these cases pursuant to Bankruptcy Rule 1015(b). 2. H.S. Die manufactures and repairs tooling and dies and serves as a

supplier of tooling to the Debtors in connection with the Debtors work for its customers.

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3.

On or about April 2, 2007, the Debtors filed the Motion, which, among

other relief, seeks to assume and assign certain executory contracts to either the proposed purchaser, Cadence Innovation, LLC (Cadence), or any other successful bidder. 4. Subsequent to the filing of the Motion, the Debtors filed and served on

H.S. Die several Sale Notices which included lists of executory contracts which may be assumed and then, subsequently, several Notices of Clerical Error Regarding Potential Assumed Agreements Related to the Debtors Interior Plastics Group Sale (the Error Notices). The Error Notices indicate that as a result of a clerical error, certain Sale Notices included [an exhibit] mistakenly identifying certain agreements as executory contracts or unexpired leases that could potentially be assumed and assigned to the Proposed Purchaser or other successful bidder The Error Notices then attempt to clarify which executory

contracts with H.S. Die that the Debtors actually seek to assume and assign pursuant to the Motion. 5. After reviewing the Sale Notices and the Error Notices provided to H.S.

Die by Debtors, H.S. Die requested and received from counsel for Debtors a final list of only two executory contracts which might be assumed and assigned. However, H.S. Die is unable to adequately identify either of the agreements or alleged executory contracts between the Debtors and H.S. Die for which the Debtors seek authority to assume and assign pursuant to the Motion. 6. Because H.S. Die is not able to adequately identify the alleged

agreements/executory contracts which the Debtors seek to assume and assign pursuant to the Motion, H.S. Die is not able to determine (a) whether it objects to the assumption and

assignment of such agreements or (b) whether there is any cure amount required prior to the proposed assumption and assignment of such agreements. WHEREFORE, for the reasons set forth in this Objection, H.S. Die respectfully requests that this Court deny the Motion unless and until (a) the Debtors more clearly identify those agreements and executory contracts they seek to assume and assign pursuant to the Motion, (b) H.S. Die is given an opportunity to review such executory contracts or agreements and object to their assumption and assignment if necessary, and (c) requiring the Debtors to promptly cure any and all defaults under any agreement or executory contract with H.S. Die which the Debtors seek to assume and assign pursuant to the Motion. Respectfully submitted, MILLER JOHNSON Counsel to H.S. Die & Engineering, Inc. Dated: May 11, 2007 By: /s/ Thomas P. Sarb Thomas P. Sarb (P27520) ecfsarbt@millerjohnson.com Robert D. Wolford (P62595) ecfwolfordr@millerjohnson.com Business Address: 250 Monroe Avenue, N.W., Suite 800 Grand Rapids, Michigan 49503 Telephone: (616) 831-1700

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