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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN --------------------------------------------------------------In re: COLLINS & AIKMAN CORP ORATION, et al.

, Debtors. ---------------------------------------------------------------

: : : : : : : :

Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered)

MOTION OF INNOVENE USA LLC FOR RELIEF FROM THE AUTOMATIC STAY TO TERMINATE CONTRACT WITH DEBTOR Innovene USA LLC, as successor in interest to BP Amoco Chemical Company (Innovene), by and through its attorneys, Kelley Drye & Warren LLP and Kupelian Ormond & Magy, P.C., for the reasons set forth in its Memorandum of Law in support of this Motion, requests relief from the automatic stay, pursuant to 11 U.S.C. 362(d)(1), to terminate Innovenes contract with Collins & Aikman Corporation, one of the above-captioned debtors. WHEREFORE, Innovene requests that the Court enter an order in the form attached hereto as Exhibit A, and grant such other relief as is just and proper. Southfield , Michigan August 25, 2005 KUPELIAN ORMOND & MAGY, P.C. By: /s/ Terrance A. Hiller, Jr. Terrance A. Hiller, Jr. (P55699) 25800 Northwestern Highway Suite 950 Southfield, Michigan 48075 Tel: 248.357.0000 Fax: 248.357.7488 tah@kompc.com and KELLEY DRYE & WARREN LLP James S. Carr Denver G. Edwards 101 Park Avenue New York, New York 10178 (212) 808-7800 ATTORNEYS FOR INNOVENE USA LLC

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EXHIBIT A

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN --------------------------------------------------------------In re: : : : COLLINS & AIKMAN CORPORATION, et al., : : Debtors. : : : ---------------------------------------------------------------

Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered)

ORDER APPROVING MOTION OF INNOVENE USA LLC FOR RELIEF FROM THE AUTOMATIC STAY TO TERMINATE CONTRACT WITH DEBTOR Upon consideration of the Motion dated August 23, 2005 of Innovene USA LLC for an Order Granting Relief from the Automatic Stay to Terminate Contract with Collins & Aikman Corporation, one of the above-captioned debtors (the Debtor) ; and it appearing that the Court has jurisdiction to consider the Motion pursuant to 28 U.S.C. 157(b)(2)(G); and it appearing that due and adequate notice of the Motion and hearing has been given; and any objections to the Motion having been overruled or withdrawn; and after due deliberation and sufficient cause appearing therefor; it is HEREBY ORDERED THAT: 1. The automatic stay as provided by 11 U.S.C. 362(a) is hereby vacated for cause,

pursuant to 11 U.S.C. 362(d)(1), to allow Innovene to provide written notice to the Debtor of termination of the contract between Innovene and the Debtor. Dated: Detroit, Michigan September __, 2005

HONORABLE STEVEN W. RHODES UNITED STATES BANKRUPTCY JUDGE

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