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

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

AMENDED OBJECTION OF FISCHER AUTOMOTIVE SYSTEMS, INC. TO NOTICE OF RECLAMATION CLAIMS THE DEBTORS DEEM TO BE VALID

NOW COMES Fischer Automotive Systems, Inc. (Fischer), by and through its undersigned attorneys, Miller, Canfield, Paddock & Stone, p.l.c., and objects to the Notice of Reclamation Claims the Debtors Deem to Be Valid (the Notice) and in support thereof states as follows: 1. On May 17, 2005 the Debtors filed voluntary petitions under Chapter 11 of

the Bankruptcy Code. (the Petition Date). On the same day, Fischer sent, and the Debtors received, a demand letter asserting a reclamation claim in the amount of $94,480.87. The claim for this amount is set forth in Exhibit A attached hereto. 2. The amount claimed by Fischer, $94,480.87, reflects payments received

from the Canadian affiliate of the Debtor that is not party to these proceedings. The total reclamation claim is this amount. For an unknown reason the Debtor lists the claim as $80,393.94.

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3.

The Debtors admit that $57,402.91 of the demand amount is proper. Of the

remainder, $2,112,76 is disputed because the goods allegedly were not in the possession of the Debtor on the date of the reclamation, $20,878.27 is disputed, allegedly because the goods were received after the Petition Date and no reason is given for the remainder.. 4. Fischer has no knowledge of the absence of any shipped goods and the

burden of demonstrating the lack of possession in on the Debtor. In the absence of such evidence, this portion of the demand should be allowed. 5. With respect to the goods allegedly received after the Petition Date, as

evidenced Exhibit A, all of the goods subject to the demand were shipped to the Debtor prior to the Petition Date. They should have been received prior to the filing. Even if some, or all, were received after the Petition Date, this does not vitiate the efficacy of a properly filed reclamation claim. 6. Finally, with respect to the difference between the demand amount,

$94,480.87, and the amount listed by the Debtor as the amount of the demand, $80.393.94, there is simply no reason or discussion of why this amount is not recognized as valid. Certainly in the absence of any explanation the total demand should be allowed. Wherefore Fischer prays this Court determine the Notice is incorrect and allow Fischer a valid reclamation claim in the amount of $94,480.87.

Respectfully submitted, MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.

By: \s\ Timothy A. Fusco Timothy A. Fusco (P13768) Attorneys for Fischer Automotive Systems, Inc. 150 West Jefferson, Suite 2500 Detroit, MI 48226 (313) 963-6420 fusco@millercanfield.com

Dated: September 28, 2005.

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