IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION,

et al. 1 Debtors. ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification # 13-3489233) Honorable Steven W. Rhodes

STATEMENT OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF COLLINS & AIKMAN CORPORATION, ET AL. WITH RESPECT TO DEBTORS MOTION FOR ORDER APPROVING A CROSS-BORDER INSOLVENCY PROTOCOL The Official Committee of Unsecured Creditors (the Committee) of Collins & Aikman Corporation, et al. (the Debtors), by and through its undersigned counsel, hereby files this statement (the Statement) with respect to Debtors Motion for Order Approving a CrossBorder Protocol (the Motion). represents as follows: In support of its Statement, the Committee respectfully

The Debtors in the above-captioned jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc.; Becker Group, LLC (d/b/a Collins & Aikman Premier Mold); Brut Plastics, Inc.; Collins & Aikman (Gibraltar) Limited; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation); Collins & Aikman Asset Services, Inc.; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.); Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.); Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.); Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.); Collins & Aikman Automotive International, Inc.; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.); Collins & Aikman Automotive Mats, LLC; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.); Collins & Aikman Automotive Services, LLC; Collins & Aikman Canada Domestic Holding Company; Collins & Aikman Carpet & Acoustics (MI), Inc.; Collins & Aikman Carpet & Acoustics (TN), Inc.; Collins & Aikman Development Company; Collins & Aikman Europe, Inc.; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.); Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.); Collins & Aikman Interiors, Inc.; Collins & Aikman International Corporation; Collins & Aikman Plastics, Inc.; Collins & Aikman Products Co.; Collins & Aikman Properties, Inc.; Comet Acoustics, Inc.; CW Management Corporation; Dura Convertible Systems, Inc.; Gamble Development Company; JPS Automotive, Inc. (d/b/a PACJ, Inc.); New Baltimore Holdings, LLC; Owosso Thermal Forming, LLC; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.); Wickes Asset Management, Inc.; Wickes Manufacturing Company.

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BACKGROUND 1. On May 17, 2005 (the Petition Date), each of the Debtors (the U.S. Debtors)

commenced with this Court a voluntary case under chapter 11 of title 11 of the United States Code (the Bankruptcy Code). 2. Since the Petition Date, the U.S. Debtors have continued in possession of their

properties, and have continued to operate and manage their businesses as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 3. On May 24, 2005, pursuant to section 1102 of the Bankruptcy Code, the United

States Trustee for the Eastern District of Michigan appointed the Committee. 4. On July 15, 2005 (the Administration Petition Date), Collins & Aikman Europe

S.A., Collins & Aikman Holdings Ltd., Collins & Aikman Automotive Ltd., Collins & Aikman Automotive Fabrics Ltd., Collins & Aikman Automotive Trim Ltd., AS Collins & Aikman UK Ltd., Collins & Aikman Automotive UK Ltd., Collins & Aikman Automotive Systems SL, Collins & Aikman Products GmbH, Collins & Aikman Holding AB, Collins & Aikman Automotive Systems AB, Collins & Aikman Automotive Holding GmbH, Collins & Aikman Automotive Systems GmbH, Collins & Aikman Automotive Trim GmbH, Dura Convertible Systems GmbH, Collins & Aikman Automotive Trim B.V.B.A., Collins & Aikman Automotive Systems (Italy) S.r.L., Collins & Aikman Automotive Holdings (Italy) S.r.L., Collins & Aikman Automotive Company Italia S.r.L., Collins & Aikman Holdings B.V., Collins & Aikman Automotive Trim B.V., Collins & Aikman Automotive s.r.o., Collins & Aikman Europe BV and Collins & Aikman Automotive Floormats Europe BV (collectively, the European Debtors), petitioned for administration orders pursuant to Schedule B1 of the English Insolvency Act of

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1986 in the Companies Court of the High Court of Justice, Chancery Division in London, England (the English Court), thereby commencing administration proceedings (the Administration) in accordance with English Insolvency Law. 5. The English Court has appointed, among others, Simon Appell and Alastair

Beveridge, individuals affiliated with Kroll Talbot Hughes (Kroll) as joint administrators of the European Debtors (collectively, the Administrators). In the Administration, the

Administrators act as agents of the European Debtors and must perform their functions in the interests of each companys creditors as a whole. 6. Upon information and belief, the U.S. Debtors are, collectively, the largest

creditors of the European Debtors on a consolidated basis. 7. On September 29, 2005, the U.S. Debtors filed the Motion seeking approval of

the Cross-Border Protocol (the Protocol) to facilitate the efficient administration of the U.S. Debtors bankruptcy cases as well as the European Debtors Administration. THE COMMITTEES STATEMENT 8. The Protocol provides, in essence, that the parties will agree to communicate and

negotiate with each other regarding the sharing of Confidential Information.2 While the Protocol does not provide the Committee or the U.S. Debtors with direct access to information or a guarantee of information regarding the European Debtors and their Administration, to date, the Committee has been receiving periodic updates from the U.S. Debtors and the Administrators

Capitalized terms not defined herein shall have the meanings ascribed to them in the Motion.

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regarding the Administration and recently participated in a productive meeting with the Administrators. The Committee is hopeful that, despite the non-binding nature of the Protocol, during the course of these cases and the Administration, the Administrators will be forthcoming in providing information to the Committee and the U.S. Debtors regarding the European Debtors and the Administration that is pertinent to the U.S. Debtors and their unsecured creditors. 9. Based on the foregoing, the Committee expresses no objection to the Protocol, but

expressly reserves of all of its rights to raise in the future any issues relating to the European Debtors and their Administration as such may impact the U.S. Debtors, their estates and their unsecured creditors. Dated: November 9, 2005 Respectfully Submitted, By: /s/ Thomas B. Radom BUTZEL LONG Thomas B. Radom (P24631) 100 Bloomfield Hills Parkway, Suite 200 Bloomfield Hills, MI 48304 Telephone: (248) 258-1413 Facsimile: (248) 258-1439 Email: radom@butzel.com AKIN GUMP STRAUSS HAUER & FELD LLP Michael S. Stamer, Esquire Philip C. Dublin, Esquire Alexis Freeman, Esquire 590 Madison Avenue New York, NY 10022-2524 Telephone: (212) 872-1000 Facsimile: (212) 872-1002 Counsel for the Official Committee of Unsecured Creditors

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