IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: In Re: Collins & Aikman

Corp., et al, Debtors. ______________________________/ QCR TECH, LLC S SECOND AMENDED OBJECTION TO CURE AMOUNTS CONTAINED IN THE ORDER APPROVING BIDDING PROCEDURES, ETC. IN CONNECTION WITH THE DEBTORS MOTION FOR THE ENTRY OF ORDERS APPROVING BIDDING PROCEDURES, SALE OF CERTAIN ASSETS OF THE DEBTORS INTERIORS PLASTICS GROUP FREE AND CLEAR OF LIENS, CLAIMS, ENCUMBRANCES AND INTERESTS AND RELATED RELIEF QCR Tech LLC, n/k/a QC Tech LLC ( QCR ), by and through its attorneys Seyburn, Kahn, Ginn, Bess & Serlin, brings this Second Amended Objection to the Cure Amounts listed for QCR in the Order Approving Bidding Procedures, Sale of Certain Assets of the Debtors Interiors Plastics Group Free and Clear of Liens, Claims, Encumbrances and Interests and related relief and in support of its Objection states as follows: 1. On April 2, 2007, the Debtors filed a Motion to approve bidding procedures and (Jointly Administered) Case No: 05-55927-SWR Chapter 11 Hon. Stephen W. Rhodes

schedule a sale hearing relating to the sale of certain assets of the Interiors Plastics Group as docket number 4408 (the Motion ). Exhibit A to the Notice was served on April 26, 2007, and was filed as docket number 4670 (the Original Notice ). The Original Notice was later

amended and served on May 4, 2007, as an attachment to the Notice of Clerical Error Regarding Assumed Agreement Related to the Debtors Interiors Plastics Group Sale, (the Amended

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Notice ). The list of contracts to be assumed changes from the Original Notice to the Amended Notice, and QCR is uncertain which contracts the Debtor intends to assume and assign. 2. 3. The Court entered an order granting the Motion as docket number 4532. Exhibit A to the Notices served on Counterparties in connection with the Motion

and the Amended Notice (hereafter the Assumption List ) lists QCR as a Counterparty, and references a number of purchase orders to be assumed by the purchaser of the assets of the Debtor (hereafter the Pre-Petition QCR Contracts ). 4. The Assumption List indicates that there are no unpaid balances due on the QCR

Contracts (each is shown on the Assumption List as $0 Cure Amount), which is correct. 5. However, the books and records of QCR indicate substantial unpaid balances on a

significant number of post-petition contracts, or substantial work in progress which will be payable upon completion of testing of the tools involved. Attached as Exhibit A-2 to this Second Amended Objection is a list of the QCR Post-Petition Contracts which QCR believes the Debtor intends to assign, including the cure amounts that QCR believes are due on each of those contracts as of June 13, 2007. Of the amounts shown, $569,710 has been invoiced and $127,960 is pending for work in process. 6. Attached as Exhibit B is the affidavit of Craig Capece, President of QC Tech,

LLC. (f/k/a QCR Tech, LLC), verifying that Exhibit A is a true, accurate and complete report of the cure amounts on the QCR Contracts. 7. To the extent any post-petition contracts are intended to be assigned, they have

not been identified to QCR. And, to the extent post-petition contracts will be assigned, neither the Debtor nor the prospective purchaser have provided adequate assurance of ability to duly perform all remaining obligations on any such post-petition contracts, as requested in the e-mails

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to Paul Wierbicki, one of the Debtor s attorneys, attached as Exhibit C. MCLA 440.2210 and 440.2609 entitle QCR to such assurances if a contract is assigned, or if reasonable grounds for insecurity exist for non-payment by the existing buyer (as they may in this case, since the entire business line to which the post-petition contracts relate is being sold). WHEREFORE, QCR respectfully requests that confirmation of the sale be denied, or assumption of the QCR Contracts be prohibited unless and until: a. Provision is made in the Order Confirming Sale and the Asset Purchase

Agreement for payment in full, either before, at, or promptly after closing of the sale, for payment of all of the amounts due or to become due to QCR on the pre-petition QCR Contracts, in accordance with attached Exhibits A and B; b. The Debtor has verified the pre petition contracts with QCR it intends to assume

and assign, the post-petition contracts it intends to assign and a list of the contracts it does not intend to assign; and c. QCR has been provided with adequate assurance that the Debtor will duly

perform any of its remaining obligations under post-petition contracts and the prospective purchaser of the North American Plastics division will be able to duly perform under any of the QCR contracts being assigned to the purchaser. SEYBURN, KAHN, GINN, BESS AND SERLIN, P.C.

By:

/s/ Leslie Stein (P31922) Attorneys for QCR Tech, LLC 2000 Town Center, Suite 1500 Southfield, MI 48075-1195 (248) 353-7620

Dated: June 28, 2007

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