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

NOTICE AND OPPORTUNITY TO RESPOND TO THE DEBTORS MOTION FOR AN ORDER EXTENDING THE DEBTORS EXCLUSIVITY PERIODS TO FILE A CHAPTER 11 PLAN AND TO SOLICIT VOTES THEREON PLEASE TAKE NOTICE THAT the above-captioned debtors (collectively, the Debtors) have filed their Motion for an Order Extending the Debtors Exclusivity Periods to File a Chapter 11 Plan and to Solicit Votes Thereon (the Motion). PLEASE TAKE FURTHER NOTICE THAT your rights may be affected. You may wish to review the Motion and discuss it with your attorney, if you have one in these cases. (If you do not have any attorney, you may wish to consult one.)

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

K&E 10685246.19

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0555927050826000000000009

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PLEASE TAKE FURTHER NOTICE THAT in accordance with the First Amended Notice, Case Management and Administrative Procedures [Docket No. 294] (the Case Management Procedures), filed on June 9, 2005, if you wish to object to the Court granting the relief sought in the Motion, or if you want the Court to otherwise consider your views on the Motion, no later than September 7, 2005 at 4:00 p.m. prevailing Eastern Time, or such shorter time as the Court may hereafter order and of which you may receive subsequent notice, you or your attorney must file with the Court a written response, explaining your position at:2 United States Bankruptcy Court 211 West Fort Street, Suite 2100 Detroit, Michigan 48226 PLEASE TAKE FURTHER NOTICE THAT if you mail your response to the Court for filing, you must mail it early enough so the court will receive it on or before the date above. PLEASE TAKE FURTHER NOTICE THAT you must also serve the documents so that they are received on or before September 7, 2005 at 4:00 p.m. prevailing Eastern Time, in accordance with the Case Management Procedures, including to: Carson Fischer, P.L.C. Attn: Joseph M. Fischer 300 East Maple Road, Third Floor Birmingham, Michigan 48009 Facsimile: (248) 664-1832 E-mail: jfischer@carsonfischer.com -and-

Response or answer must comply with Rule 8(b), (c) and (e) of the Federal Rules of Civil Procedure.

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Kirkland & Ellis LLP Attn: Richard M. Cieri, Esq. Citigroup Center 153 East 53rd Street New York, NY 10022 Facsimile: (212) 446-4900 E-mail: rcieri@kirkland.com -andKirkland & Ellis LLP Attn: David L. Eaton, Esq. Ray C. Schrock, Esq. Marc J. Carmel, Esq. 200 East Randolph Drive Chicago, Illinois 60601 Facsimile: (312) 861-2200 E-mail: deaton@kirkland.com rschrock@kirkland.com mcarmel@kirkland.com PLEASE TAKE FURTHER NOTICE THAT if no responses to the Motion are timely filed and served, the Court may grant the Motion and enter the order without a hearing as set forth in Rule 9014-1 of the Local Rules for the United States Bankruptcy Court for the Eastern District of Michigan.

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Dated: August 26, 2005

KIRKLAND & ELLIS LLP /s/ Marc J. Carmel Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 300 East Maple Road, Third Floor Birmingham, Michigan 48009 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

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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

NOTICE OF HEARING PLEASE TAKE NOTICE that a hearing on the above-captioned Debtors Motion for an Order Extending the Debtors Exclusivity Periods to File a Chapter 11 Plan and to Solicit Votes Thereon (the Motion) is scheduled to be heard before the Honorable Steven W. Rhodes on September 12, 2005 at 2:00 p.m., or as soon thereafter as counsel may be heard, in his courtroom in the United States Bankruptcy Court, 211 W. Fort Street, Detroit, Michigan 48226. PLEASE TAKE FURTHER NOTICE that if no responses to the Motion are timely filed and served, the Court may grant the Motion and enter the order without a hearing as

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

K&E 10685246.19

set forth in Rule 9014-1 of the Local Rules for the United States Bankruptcy Court for the Eastern District of Michigan. Dated: August 26, 2005 KIRKLAND & ELLIS LLP /s/ Marc J. Carmel Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 300 East Maple Road, Third Floor Birmingham, Michigan 48009 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

2
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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
Hearing Date (if necessary): September 12, 2005 at 2:00 p.m. Objection Deadline: September 7, 2005 at 4:00 p.m.

DEBTORS MOTION FOR AN ORDER EXTENDING THE DEBTORS EXCLUSIVITY PERIODS TO FILE A CHAPTER 11 PLAN AND TO SOLICIT VOTES THEREON The above-captioned debtors (collectively, the Debtors) hereby move the Court (the Motion) for the entry of an order, substantially in the form of Exhibit A, extending the Debtors exclusivity periods to file a chapter 11 plan and to solicit votes thereon. In support of this Motion, the Debtors respectfully state as follows: 1. The Debtors exclusive period to file a plan is currently scheduled to expire

on September 14, 2005, only four months from the time these chapter 11 cases the largest cases
1

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 05-55991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 05-55964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

K&E 10685246.19

filed this year in the United States were filed. The sheer size and complexity of the Debtors cases provides sufficient cause to extend the exclusivity periods, particularly because this is the Debtors first request to extend the periods. The substantial progress that has been made, in the face of significant obstacles, further supports the requested extension. Finally, the Debtors require the additional time to complete the evaluation of their businesses and operations, assess restructuring alternatives and develop a viable and consensual plan of reorganization. Jurisdiction 2. The Court has jurisdiction over this matter pursuant to 28 U.S.C. 1334.

This matter is a core proceeding within the meaning of 28 U.S.C. 157 (b)(2). 3. 4. Venue is proper pursuant to 28 U.S.C. 1408 and 1409. The statutory basis for the relief requested herein is section 1121 of the

Bankruptcy Code, 11 U.S.C. 101-1330 (the Bankruptcy Code). Background 5. On May 17, 2005 (the Petition Date), the Debtors filed their voluntary

petitions for relief under chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses and managing 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, the Court entered an order jointly administering these cases pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure. 6. On May 24, 2005, the United States Trustee appointed an official committee

of unsecured creditors pursuant to section 1102 of the Bankruptcy Code (the Committee). 7. The Debtors and their non-debtor affiliates are leading global suppliers of

automotive components, systems and modules to all of the worlds largest vehicle manufacturers, including DaimlerChrysler AG, Ford Motor Company, General Motors Corporation, Honda Motor

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Company, Inc., Nissan Motor Company Unlimited, Porsche Cars GB, Renault Crateur D Automobiles, Toyota SA and Volkswagen AG. Relief Requested 8. By this Motion, the Debtors request the entry of an order, pursuant to section

1121(d) of the Bankruptcy Code, extending the Debtors exclusive period to file a chapter 11 plan for approximately an additional 150 days from September 14, 2005 through and including February 13, 2006, and extending the Debtors exclusive period to solicit acceptances of such plan or plans for an additional 150 days from November 13, 2005 through and including April 12, 2006, without prejudice to their rights to seek additional extensions thereof. Basis for Relief 9. Section 1121(b) provides for an initial period of 120 days after the

commencement of a chapter 11 case during which a debtor has the exclusive right to propose and file a chapter 11 plan or plans (the Plan Proposal Period). Section 1121(c)(3) provides that, if the debtor files a plan within the Plan Proposal Period, the debtor has a period of 180 days after the commencement of the case to solicit and obtain acceptances of such plan or plans, during which time competing plans may not be filed (the Solicitation Period, and together with the Plan Proposal Period, the Exclusivity Periods). I. Purpose and Policy Underlying the Exclusivity Periods 10. The principal goal of chapter 11 is the successful rehabilitation of a debtors

businesses, which serves to, among other things, increase the pool of assets available for distribution to creditors. See NLRB v. Bildisco & Bildisco, 465 U.S. 513, 527 (1984); United States v. Whiting Pools, Inc., 462 U.S. 198, 203 (1983). See also H.R. Rep. No. 595, 95th Cong., 1st Sess. 220 (1977) (hereinafter, House Report).

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11.

The provisions of chapter 11 reflect Congressional intent that the principal

means of successful rehabilitation should be a considered and consensual plan. See, e.g., In re Perkins, 71 B.R. 294, 297 (W.D. Tenn. 1987). Such plans reduce the administrative burden imposed upon the bankruptcy court, avoid liquidations, preserve jobs, prevent lengthy and costly litigation and increase the overall distribution to creditors and equity security holders. See Fortgang & Mayer, Valuation in Bankruptcy, 32 U.C.L.A. L. Rev. 1061, 1106-7 (1985). 12. To promote balanced and successful reorganizations under chapter 11,

Congress gave debtors the exclusive right to propose a plan and solicit acceptances of the plan through the exclusivity provisions set forth in section 1121. The flexibility of section 1121 is intended to give debtors an adequate opportunity to stabilize business operations at the outset of a chapter 11 case and to negotiate an effective plan of reorganization with creditors and other constituencies. See In re Newark Airport/Hotel L.P., 156 B.R. 444, 451 (Bankr. D. N.J. 1993), affd, 155 B.R. 93 (D. N.J. 1993) (noting that chapter 11 provisions are designed to enable a debtor to remain in control, thereby making reorganization an attractive alternative to financially troubled companies); Perkins, 71 B.R. at 297-98 (noting that section 1121 is designed to give debtors time to reach an agreement with its creditors regarding a plan of reorganization). II. Legal Standard for Extending the Exclusivity Periods 13. When the Exclusivity Periods do not provide a chapter 11 debtor with

sufficient time to propose a plan, then section 1121(d) authorizes the bankruptcy court to extend the periods for cause. See 11 U.S.C. 1121(d) (On request of a party in interest made within the respective periods specified in subsections (b) and (c) of this section and after notice and hearing, the court may for cause reduce or increase the 120-day period or the 180-day period referred to in this section.); In re Service Merchandise Co., Inc. et al., 256 B.R. 744, 751 (Bankr. M.D. Tenn. 2000), citing In re All Seasons Indus., Inc., 121 B.R. 1002 (Bankr. N.D. Ind. 1990). Indeed,

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Congress recognized that, depending on the circumstances, a 120-day exclusivity period may not afford a debtor sufficient time to formulate a plan. See House Report, at 232 (The court is given the power . . . to increase or reduce the 120-day period depending on the circumstances of the case. For example, if an unusually large company were to seek reorganization under chapter 11, the court would probably need to extend the time in order to allow the debtor to reach an agreement. (footnotes omitted)); see also In re Timbers of Inwood Forest Associates, Ltd., 808 F.2d 363 (5th Cir. 1987), affd, 484 U.S. 365 (1988). 14. Although the Bankruptcy Code does not define cause required to justify an

extension of the Exclusivity Periods, the legislative history and case law indicates that bankruptcy courts should be flexible to promote the orderly, consensual and successful reorganization of a debtors affairs. See House Report, at 232; In re The Elder Beerman Stores Corp., 1997 U.S. Dist. LEXIS 23785, *4 (S.D. Ohio 1997) (a bankruptcy court has a high degree of flexibility in determining whether cause exists to extend the exclusivity period); see also In re AMKO Plastics, Inc., 197 B.R. 74, 77 (Bankr. S.D. Ohio 1996) (the for cause standard in determining an exclusivity extension leave[s] the question to the reorganization court in the exercise of its discretion and to promote maximum flexibility to suit various types of reorganization proceedings); In re RCN Anlagenivestitionen Frodsgesellschaft II-Kommanditgesselschaft, 118 B.R. 461, 462 (W.D. Mich. 1990) (same). 15. In applying the flexible standard to determine whether cause exists to

extend the Exclusivity Periods, courts have considered a wide variety of factors, each of which may provide sufficient grounds for extending the Exclusivity Periods. See, e.g., In re Dow Corning Corp., 208 B.R. 661, 664 (S.D.N.Y. 1983); AMKO, 197 B.R. at 77; In re Express One Intl, Inc., 194 B.R. 98, 100 (Bankr. E.D. Tex. 1996); In re McLean Indus., Inc., 87 B.R. 830, 834 (Bankr. S.D.N.Y. 1987).

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16.

Among the factors that courts analyze are the following: (a) the size and

complexity of the chapter 11 case;2 (b) the debtors progress in the chapter 11 case;3 and (c) whether an extension of the Exclusivity Periods will harm the debtors creditors.4 Although courts use a variety of factors to determine whether a debtor has established cause to extend the Exclusivity Periods, the primary consideration should be whether or not doing so would facilitate moving the case forward. Dow Corning, 208 B.R. at 664-670 (analyzing list of eight factors which are mostly subsumed within the list above before concluding that the most important factor is the practical call of whether the extension would facilitate progress within the case). 17. As evinced below, sufficient cause exists to grant the Debtors requested

extension of the Exclusivity Periods. The requested extension of the Exclusivity Periods is both appropriate and necessary to afford the Debtors sufficient time to evaluate strategic and financial alternatives and to negotiate a plan setting forth appropriate distributions to creditors. III. The Debtors Situation Meets the Cause Standard A. The Debtors Chapter 11 Cases are Large and Complex 18. The most common bases upon which courts grant extensions of the

Exclusivity Periods is the size and complexity of the chapter 11 case. See, e.g., Express One Intl, 194 B.R. at 100; Texaco, 76 B.R. at 326 (finding cause to extend exclusivity based on size of cases); In re Manville Forest Prods. Corp., 31 B.R. 991, 995 (S.D.N.Y. 1973) (same). Congress specifically recognized that courts may need to extend the Exclusivity Periods for unusually large or complex cases.
2 3

See House Report, at 232 ([I]f an unusually large company were to seek

See, e.g., Elder Beerman, 1997 U.S. Dist. LEXIS 23785, *4; In re Texaco, Inc., 76 B.R. at 322, 326-27 (Bankr. S.D.N.Y. 1987). See, e.g., McLean, 87 B.R. at 834; Jasik v. Conrad (In re Jasik), 727 F.2d 1379, 1382 (5th Cir. 1984); AMKO, 197 B.R. at 77; Service Merchandise, 256 B.R. at 751. See, e.g., In re Grand Traverse Devp Co. Ltd. Partnership, 147 B.R. 418, 420 (Bankr. W.D. Mich. 1992); In re Gibson & Cushman, 101 B.R. 405, 409 (E.D.N.Y. 1989).

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reorganization under chapter 11, the court would probably need to extend the time in order to allow the debtor to reach an agreement.). 19. The Debtors cases are the largest filed in the United States this year and

among the largest ever in this district, and there can be little dispute that they are complex. The Debtors comprise a large, multifaceted national and international enterprise with numerous businesses, operations and financial interests throughout the United States and around the world. 20. There are 38 debtor entities with domestic and foreign operations. The

operations of the Debtors and their affiliates generate approximately $4 billion in combined revenue and employ approximately 23,000 employees worldwide. The Debtors operate approximately 50 plants in the United States, with approximately an additional 50 plants operated through international non-Debtor affiliates. 21. Moreover, the unique interworkings of the automobile industry add an

additional layer of complexity on the Debtors already challenging financial and operational situation. For example, just in time inventory has required the Debtors, from the first day of the cases, to address supplier issues on extremely tight timetables. The Debtors are forced to spend a significant amount of time and energy ensuring a steady supply of product for fear that even the slightest shortfall or delay in shipments can put the Debtors ability to timely supply their customers at risk and lead to an immediate threat of shutdown. Any such shutdown could have a material, detrimental effect on the Debtors estates and creditor recoveries. 22. The Debtors 24 European affiliates generate revenue of approximately

$1 billion annually. These affiliates did not file for chapter 11 and are not part of the Debtors bankruptcy. After the Petition Date, however, the Debtors spent considerable time addressing the severe financial condition of the European operations and pursuing strategies designed to stabilize those operations and preserve the value of those assets. On July 15, 2005, these European affiliates

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filed administrative proceedings (the closest European equivalent of chapter 11) in the United Kingdom. The coordination and management of the concurrent proceedings in the United States and the United Kingdom have further complicated the Debtors cases. As the largest creditor and the ultimate parent of each of the European entities, the outcome of the restructuring of each of these entities could be crucial to the value of the Debtors. 23. The Debtors respectfully submit that the size and complexity of these cases

alone constitute sufficient cause to grant the Debtors initial request to extend the Exclusivity Periods. B. The Debtors Progress and Efforts Over the Coming Months 24. Courts have held that to further chapter 11s rehabilitative purpose, a debtor

should be given a reasonable opportunity to negotiate and develop an acceptable plan with creditors and to prepare adequate financial and non-financial information concerning the ramifications of any proposed plan for disclosure to creditors. See, e.g., Dow Corning, 208 B.R. at 664; see also McLean, 87 B.R. at 833-34; Texaco, 76 B.R. at 327. Courts often consider a debtors progress during the initial stages of a case toward the development of a consensual plan. See, e.g., McLean, 87 B.R. at 834; In re United Press Intl, 60 B.R. 265, 269-70 (D.C. 1986). The Debtors and their professionals have worked in a direct and deliberate manner to ensure that these cases proceed as quickly as possible to effectuate the Debtors rehabilitation and develop a consensual plan of reorganization. 25. The difficult situation in which the Debtors professionals and the new

management found themselves is well known to the Debtors major constituencies. The Debtors restructuring professionals were introduced to the Debtors situation approximately 72 hours before the chapter 11 filings with the Debtors facing a number of extremely difficult hurdles.

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Significantly, the professionals did not have the weeks or months typical (and necessary) to prepare a large and complex bankruptcy case for a chapter 11 filing. 26. The Debtors and their professionals immediately needed to compile credible

financial and operational information to make key decisions. This was particularly important because the Debtors were operating without a business plan and with significant gaps in the management team. Companies generally maintain this type of information on a daily basis, but the Debtors were forced to prepare it while operating in a stressed environment with limited personnel. 27. Moreover, before the Petition Date, the Debtors had been operating with

almost no working capital, had no source of liquidity and were highly leveraged. At the time of the Debtors filings, among other things, the Debtors had a negative cash balance and faced imminent interruptions in production. Numerous vendors had stopped shipping product and inventories were nearly depleted. Cash was needed on an immediate basis to continue operations. Cash management systems were in disarray. Further, the Debtors organizational structure had been flattened to the point where key personnel were absent from critical management areas. The Debtors had to convince vendors, many of whom had been stung by the bankruptcy, to continue to ship products so that the Debtors could continue to operate. 28. The Debtors internal problems described above were further exacerbated by

a number of external forces outside of their control. Raw material costs, in particular resin and steel, have continued to increase. For the most part, the Debtors had no contractual right to pass these costs along to their customers. Additionally, the automotive industry is generally in a very difficult cycle. This has led customers to demand price decreases (while the Debtors are seeking price increases). At the same time, the Debtors suppliers are less willing to extend credit to the Debtors as the suppliers are addressing their own problems.

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29.

Despite the difficulties and complexities described above, in the months since

the Petition Date, the Debtors have made significant progress while maintaining the operations of one of the largest automotive parts suppliers. The Debtors have made strides towards addressing their immediate working capital demands, stabilizing vendor relationships, understanding and diagnosing operational problems, enhancing the quality of the management team, analyzing and renegotiating unprofitable contracts and formulating a business plan that incorporates potential revenue increases and cost cutting. The following is a short list detailing the progress made on a number of significant matters, but certainly not all, since the filing of these chapter 11 cases. i. 30. The Debtors New Management Team As of the Petition Date, the Debtors had insufficient human resources to

engage in the difficult restructuring necessary to create a viable enterprise. The Debtors quickly pursued additional resources to assist in the reorganization and have begun building an experienced management team to lead the Debtors through the next phase of the restructuring process. 31. Just prior to the Petition Date, the Debtors retained KZC Services, Inc. as

restructuring advisors and hired John R. Boken as Chief Restructuring Officer. Before joining the Debtors, among other positions, Mr. Boken served as President and Chief Operating Officer of NRG Energy, Inc., guiding that corporation through Chapter 11 and completing a $10 billion debt restructuring. 32. To address operational needs, Frank E. Macher was hired as President and

Chief Executive Officer in July 2005. Mr. Macher has significant operational experience in the automotive industry. Mr. Macher was the Chairman of the Board and Chief Executive Officer of Federal-Mogul Corporation during its bankruptcy proceedings. Before that, he served as President and Chief Executive Officer of ITT Automotive, a global automotive parts supplier, and as the Vice President and General Manager of the Automotive Components Division of Ford Motor Company.

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33.

Concurrently, the Debtors appointed Stephen F. Cooper as Chairman of the

Board of Directors and Leonard J. LoBiondo as a Director. Each of these individuals brings a wealth of restructuring experience to the Debtors. Mr. Cooper is the Chairman and Mr. LoBiondo is a Senior Managing Director and Co-Chief Operating Officer of Kroll Zolfo Cooper. Mr. Cooper has more than 30 years experience leading companies through operational and financial restructurings and currently acts as interim CEO of Krispy Kreme Doughnuts, Inc. and Enron Corp. Mr. LoBiondo has more than 18 years experience as a restructuring specialist. 34. In addition, the Debtors established a Restructuring Committee of its Board

of Directors that is now responsible for overseeing the development of a business plan, the valuation of the businesses and, ultimately, the negotiation of a plan of reorganization. The Debtors are continuing to supplement the current management team with individuals with industry experience. 35. The entire Board of Directors is actively involved in the reorganization. The

Board of Directors has maintained weekly meetings over the past several months and has scheduled additional meetings to address particular issues that require more immediate attention. Additionally, individual members of the Board of Directors have focused on specific issues, including assisting with the improvement of the management team, communicating with major constituencies regarding the Debtors activities and analyzing the Debtors long-term options. 36. Although the Debtors believe the changes in management have assisted in

moving the Debtors towards the formation of a consensual and viable plan of reorganization, the transition has also created certain delays in the ability to develop a plan. Now that these executives are in place (or are soon to be in place) and actively working on a business plan going forward, the Debtors believe that they are completing the steps necessary to propose a plan of reorganization.

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ii. 37.

Securing Debtor in Possession Financing As of the Petition Date, the Debtors did not have any cash on hand and did

not have any way of generating unencumbered cash to finance operations. This made securing and obtaining approval of financing a necessary focus at the beginning of the Debtors filings. Thus far, the Debtors have had to seek approval for three separate financing arrangements. The negotiation and approval of each of these debtor-in-possession financing transactions has required significant resources of the Debtors in the initial stages of these cases. In fact, the last of these financing deals was approved on a final basis only two weeks ago, on August 11, 2005. 38. Initially, on the Petition Date, the Court entered an order granting the Debtors

interim authority to borrow $150 million in debtor-in-possession financing from JPMorgan Chase Bank, who also served as the agent for the Debtors prepetition lender group. This debtor-inpossession financing was approved on a final basis on July 25, 2005, but the financing was limited to the $150 million that the Debtors already had exhausted. To address their further cash needs during the first weeks of these cases, on June 23, 2005, the Debtors sought authority to borrow an additional $30 million from their largest customers. Most recently, on August 11, 2005, the Debtors sought and obtained approval of the Customer Financing Agreement that provided the Debtors with, among other things, $82.5 million in immediate price increases, $82.5 million in additional financing and a definitive timetable for the renegotiation of contracts and formulation of a business plan.5 39. The Customer Financing Agreement will provide the Debtors with necessary

liquidity through October 1, 2005, during which time, the Debtors will continue to focus on the

The Motion for Interim and Final Orders (I) Authorizing the Debtors to (a) Obtain Post-Petition Secured Financing and (b) Utilize Cash Collateral and (II) Granting Adequate Protection to Pre-petition Secured Parties requested that the Court approve the Debtors entry into an agreement (the Customer Financing Agreement) with its customers. A final order approving the Customer Financing Motion was entered on August 11, 2005.

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business plan and progress towards the development of a financially viable enterprise. As described more fully below, the Debtors are also addressing their unprofitable contracts with a goal towards renegotiating the terms so that the contracts are profitable and seeking to reject those that cannot be renegotiated. iii. 40. Establishment of Cash Management System Continuation as a going concern rested in large part on the Debtors ability to

accurately track and forecast cash needs to avoid any cash shortfalls that might interrupt operations. Thus, within the first several weeks of these cases, the Debtors financial advisors began producing a daily cash report to provide management, the treasury department and the purchasing department with an understanding of the cash flow performance and ongoing cash requirements of the businesses. This enabled the Debtors to forecast and then adjust their cash needs to operate in a more stable and predictable manner. The Debtors also have made strides to better understand the segregation of the Debtors accounts, categorize remittances and cash inflows and outflows appropriately and manage the liquidity position of the businesses on a daily basis. While the Debtors continue to improve their accounting systems and cash management processes, the Debtors and their financial advisors have made significant progress toward understanding and managing the liquidity issues that had plagued the Debtors before the Petition Date. Additionally, the Debtors now are able to generate credible forecasts. iv. 41. Managing the Debtors Supply Chain The Debtors do business with over 700 materials vendors. After the Petition

Date, many of the Debtors vendors sought changes in business terms, including transitioning to cash on delivery or even cash in advance terms to continue shipping. Negotiating with and

resolving the concerns of such vendors has required considerable efforts by the Debtors and their

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professionals. Despite these challenges, since the Petition Date, the Debtors have been able to avoid material interruptions in production. v. 42. Addressing Case Administration Matters The Debtors have accomplished a number of other tasks during the course of

the chapter 11 proceedings. These include: preparing and filing Schedules and Statement of Financial Affairs for all 38 Debtors on August 12, 2005, which included over 3,600 pages and listed approximately 2,000 creditors; handling a number of motions requesting relief from the automatic stay; analyzing unprofitable unexpired leases and rejecting certain leases and seeking and obtaining Court approval under section 365(d)(4) to extend the deadline to assume or reject the Debtors remaining unexpired leases; reviewing approximately 150 reclamation demands from vendors requesting that the Debtors return approximately $20 million of goods; and negotiating consensual resolution of numerous requests for adequate assurance of future performance from utilities. vi. 43. Analysis, Renegotiation and Rejection of Contracts and Formulation of a Business Plan The Customer Financing Agreement described above requires that the

Debtors formulate a business plan by August 31, 2005, and establishes an aggressive schedule for the analysis and renegotiation of unprofitable contracts. To accomplish these tasks, the Debtors senior management and the Debtors advisors have dedicated extensive resources to the task of identifying the component parts they manufacture and determining the profitability and strategic benefit to the Debtors of each of those parts. This has required a detailed and extensive analysis as each part may be subject to numerous contracts, with each contract potentially having numerous amendments. 44. There are literally thousands of parts involved in this analysis, and each part

is one piece in a larger component. As an under-priced component is identified, the Debtors must

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evaluate each of the parts for that component and determine how the negotiations with the customers regarding the component may impact other negotiations. 45. Determining how raw material price increases have affected the cost of

manufacturing parts has been a necessary piece of the process, but also a very challenging one. Resins are an important ingredient of the Debtors parts. Recently the price of resins has increased dramatically with the price of fuel, and the Debtors are attempting to pass along some of these costs to customers through price increases. This requires a precise knowledge of the cost of the resin used to manufacture each part. This is complicated by the fact that there are many types of resins, each with a different price. And resins are just one of many ingredients that the Debtors have to consider to determine the costs to produce their goods. 46. Nonetheless, the Debtors have been committed to expeditiously renegotiating

and, if necessary, rejecting burdensome contracts and closing unprofitable plants. In fact, as of the filing of this Motion, the Debtors have completed the analysis as to the profitability of most of the significant contracts to be addressed in this process and have already begun the process of meeting with and renegotiating unprofitable contracts. 47. Further, as required by the Customer Financing Agreement and in the context

of identifying larger issues relevant to the development of a successful plan, the Debtors and their advisors have begun a comprehensive evaluation of their entire business model to rationalize certain operations and evaluate the efficiencies of the Debtors businesses. This evaluation is critical to the development of a sustainable business plan because the Debtors believe that a tremendous amount of efficiency can be gained in evaluating the plant layout and centralizing the Debtors purchasing and financial systems, which systems evolved from the amalgamation of acquired companies rather than from a disciplined approach. Indeed, the Debtors have already formulated and presented to the

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Board of Directors an outline of the business plan, and the Debtors are on target to complete the plan by the August 31, 2005 deadline. 48. The business plan will start with a thorough analysis of the businesses in their

current form. This will include pro forma financial statements based on assumptions of continuing operations under the Debtors current business model. 49. Because the Debtors recognize that operating their businesses based on the

existing model is not a viable alternative, the Debtors are pursuing a number of operating fixes in connection with developing the business plan. One significant fix is the contract renegotiations that have been underway since the Petition Date and have been addressed through the formalized process as part of the Customer Financing Agreement. significant, are far from the Debtors only initiative. 50. The process of understanding the business plan has included extensive The contract renegotiations, while

communications with the Debtors major constituencies. The Debtors have involved a number of parties, including the Committee, the prepetition and postpetition secured lenders and the major original equipment manufacturers in their discussions regarding operating performance, infrastructure issues, and all other major aspects of their operations. These parties and their

professionals have significant access to the Debtors senior management, Board of Directors, professionals and other personnel. In fact, the communications include over 40 professionals from the Debtors major constituencies being permanently stationed at the Debtors headquarters, daily in-person and telephone conferences and operational and financial reports being shared. 51. The Debtors have begun to consider and implement other aggressive cost-

reduction initiatives, particularly with respect to materials costs. Additionally, the Debtors are evaluating the entire manufacturing process to identify and eliminate unnecessary costs. To

accomplish this, the Debtors are, among other things, determining how to minimize waste,

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evaluating plant configuration and engaging in a comprehensive buy v. build analysis to minimize unnecessary or unprofitable undertakings that are more cheaply and efficiently outsourced. 52. All of these decisions are entwined because the Debtors decisions in one area

directly affect other aspects of the restructuring. For example, the Debtors have approximately fifty domestic plants for which it is reviewing the plant configuration to use their space in the most efficient manner. Once the Debtors renegotiate with their customers and determine which contracts will be renegotiated and which will be rejected, they will know how much capacity they need. But the process is iterative because as the costs change, so do the Debtors need for price adjustments. 53. At the same time, the Debtors are considering to what extent it can increase The Debtors are evaluating their competitive

revenue in a way that also increases profits.

advantages and analyzing how to leverage those advantages. 54. While developing the business plan, the Debtors also are working on their

financing plan. In this process, the Debtors and their advisors are analyzing the Debtors capital structure before the bankruptcy, reviewing the capital structures of the Debtors competitors and businesses in different industries and determining the most appropriate way to finance the Debtors plan. 55. After all of these analyses are complete, the Debtors and their advisors expect

to have a stand-alone business model against which all of the Debtors alternatives can be compared. 56. The discussions regarding these alternatives already have begun. For

example, since the appointment of the Committee, the Debtors have engaged in formal and informal discussions with their prepetition secured lenders and the Committee to explore restructuring alternatives and mechanisms to maximize the value of the Debtors estates, including the consolidation of certain business segments of the Debtors businesses, the sale of the Debtors entire

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operations as a going concern and separate sales of the Debtors divisions. The Debtors and their professionals also have communicated with their other major constituencies to provide information about their continuing restructuring efforts. In furtherance of this process, the Debtors have been engaged in extensive due diligence efforts with many of their constituencies on a variety of issues related to the development of the Debtors plans. 57. To be sure, creation of the business plan is the first step towards the

development and success of the viable plan of reorganization. This process, while being undertaken at an aggressive pace, is not complete. The Debtors believe that an extension of the Exclusivity Periods is appropriate to ensure that the Debtors have an adequate opportunity to finalize the business plan and propose a plan of reorganization based thereon without the distraction of addressing competing plans that may be filed. 58. These tasks have occupied the vast majority of the Debtors resources in the

early phases of these cases. The Debtors, however, have made significant advances towards understanding and developing a business model to transform into a viable plan of reorganization and expect to use the next several months to work towards achieving these goals. C. The Extension of the Exclusivity Periods Will Not Prejudice Creditors 59. The extensions of the Exclusivity Periods as requested will provide the

Debtors and other parties-in-interest an opportunity to develop fully the framework upon which serious negotiations toward a plan of reorganization can be based. Affording the Debtors a full opportunity to undertake an extensive review and analysis of their businesses and properties, so that they may develop a business plan and a plan of reorganization that satisfies the requirements of chapter 11, will not harm creditors. 60. Alternatively, allowing the Exclusivity Periods to expire before this process

and the negotiations have been completed would defeat the very purpose of Section 1121 to

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afford the Debtors a meaningful and reasonable opportunity to negotiate with creditors and propose and confirm a consensual plan of reorganization. 61. Despite all the progress that has been made, there are still significant issues

that need to be addressed. The Debtors need to secure long-term financing to fund operations, negotiate permanent price increases from their customers and substantially lower the costs to produce goods. Each of these aspects of the Debtors future depends on third parties willingness to do business with the Debtors. The Debtors are working to convince their key constituencies that developing long-term relationships will benefit all parties, which requires the stability and attention from the Debtors and their advisors that is made possible by the Exclusivity Periods. 62. The Exclusivity Periods have allowed the Debtors to pursue this difficult and

necessary work without the distractions of other parties filing competing plans. Without this opportunity, the Debtors resources would no doubt be pulled in unproductive directions such that the value of the estates would quickly dissipate to the detriment of all creditors and parties-ininterest. Therefore, the Debtors respectfully request that the Court extend the Exclusivity Periods for the Debtors to file a plan of reorganization and solicit votes thereon. 63. Moreover, the Debtors request is reasonable in light of relief granted in other

similar cases. This Court and other courts routinely grant lengthy extensions of the Exclusivity Periods in large reorganization cases. See, e.g., In re UAL Corp., Case No. 02-48191 (ERW) (Bankr. N.D. Ill. March 24, 2003) (initial extension of exclusivity periods for six months); In re Kmart Corp., Case No. 02-24795 (Bankr. N.D. Ill. July 30, 2002) (initial extension of exclusivity periods more than nine months); In re Enron Corp., Case No. 01-16034 (AJG) (Bankr. S.D.N.Y. April 24, 2002) (initial extension of exclusivity periods for six months); In re Bethlehem Steel Corp., Case No. 01-15288 (BRL) (Bankr. S.D.N.Y. Feb. 5, 2002) (initial extension of exclusivity periods for five and one-half months); In re Casual Male Corp., Case No. 01-41404 (REG) (Bankr.

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S.D.N.Y. May 18, 2001) (initial extension of exclusivity periods for six months); In re Service Merchandise, Inc., Case No. 99-02649 (Bankr. M.D. Tenn. May 25, 1999) (initial extension of exclusivity periods for seven months); see also In re Intermet Corp., Case No. 04-67597 (MBM) (Bankr. E.D. Mich. Aug. 25, 2005) (exclusivity periods extended for at least seven months); In re Meridian Automotive Systems-Composites Operations Inc., Case No. 05-11168 (Bankr. D. Del. Aug. 11, 2005) (MFW) (initial extension of exclusivity of four months); In re Tower Automotive, Inc., Case No. 05-10578 (Bankr. S.D.N.Y. May 25, 2005) (ALG) (initial extension of exclusivity periods of four months). 64. Although the Debtors are mindful of the desire of creditors and all parties-in-

interest for the Debtors to emerge from chapter 11 quickly, for the foregoing reasons the Debtors require the additional time requested herein to afford them the ability to develop a plan of reorganization. Notice 65. Notice of this Motion has been given to the Core Group and Affected Parties

as required by the Case Management Procedures.6 In light of the nature of the relief requested, the Debtors submit that no further notice is required. No Prior Request 66. other court. No prior motion for the relief requested herein has been made to this or any

Capitalized terms used in this paragraph 65 not otherwise defined herein shall have the meanings set forth in the First Amended Notice, Case Management and Administrative Procedures [Docket No. 294].

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WHEREFORE, the Debtors respectfully request an entry of an order, substantially in the form attached hereto as Exhibit A, (a) extending the Plan Proposal Period from September 14, 2005 to February 13, 2006, (b) extending the Solicitation Period from

November 13, 2005 to April 12, 2006 and (c) granting such other further relief as is just and proper. Dated: August 26, 2005 KIRKLAND & ELLIS LLP /s/ Marc J. Carmel Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 300 East Maple Road, Third Floor Birmingham, Michigan 48009 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

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EXHIBIT A

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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

ORDER EXTENDING THE DEBTORS EXCLUSIVITY PERIOD TO FILE A CHAPTER 11 PLAN AND TO SOLICIT VOTES THEREON Upon the motion (the Motion)2 of the above-captioned debtors (collectively, the Debtors) for an Order Extending the Debtors Exclusivity Period to File a Chapter 11 Plan and to Solicit Votes Thereon; it appearing that the relief requested is in the best interests of the Debtors estates; it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; it appearing that this proceeding is a core proceeding pursuant to 28

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968. Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Motion.

K&E 10685246.19

U.S.C. 157(b)(2); it appearing that venue of this proceeding and this Motion in this District is proper pursuant to 28 U.S.C. 1408 and 1409; it appears that notice of this Motion and the opportunity for a hearing on this Motion was appropriate under the particular circumstances and that no other or further notice need by given; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED 1. 2. The Motion is granted in its entirety. The Plan Proposal Period is extended by 152 days from September 14, 2005 to

February 13, 2006. 3. The Solicitation Period is extended by 150 days from November 13, 2005, to

April 12, 2006. 4. This relief is without prejudice to the Debtors right to seek a further extension of

the Exclusivity Periods. 5. The Debtors are authorized to take all actions necessary to effectuate the relief

granted pursuant to this Order in accordance with the Motion. 6. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 7. The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order. Dated: __________________, 2005 United States Bankruptcy Judge

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