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

11 Case No. 05-55927 (SWR) (Jointly Administered) Case No. 05-55932

COLLINS & AIKMAN PRODUCTS COMPANY, COLLINS & AIKMAN CANADA, INC., et al.,

Bankruptcy Judge Steven W. Rhodes

AMENDED REQUEST FOR ALLOWANCE OF ADMINISTRATIVE CLAIM Pursuant to the Notice of Effective Date of the First Amended Joint Plan of Collins & Aikman Corporation and Its Debtor Subsidiaries and Related Deadlines, Notice of Administrative Claims Bar date and Deadline for Final Fee Application dated October 12, 2007 and Section 365 and 503 of the United States Bankruptcy Code (the Bankruptcy Code), Relational, LLC, Relational Funding Corporation, Relational Technology Services, and Relational Funding Canada Corporation (collectively, Relational) hereby files this Amended Request for Allowance of Administrative Expense Claim against Collins & Aikman Corp., Collins & Aikman Products Company (CAPC), and Collins & Aikman Canada, Inc. (CACI) et al. In support hereof, Relational respectfully states as follows: 1. Prior to the filing of the above-captioned chapter 11 cases on May 17, 2005, the

(Petition Date), Relational entered into Master Equipment Lease Agreements and Schedules related thereto with CAPC and CACI (collectively, as amended from time to time, the PrePetition Leases.) Pursuant to the Pre-Petition Leases, Relational leased to CAPC and CACI certain computer and related equipment in exchange for regular lease payments.

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After the Petition Date, Relational entered into additional lease agreements with

CAPC and CACI (the Post-Petition Leases, and, together with the Pre-Petition Leases, the Equipment Leases). 3. On August 29, 2007, the Debtors filed their Second Amended Exhibit F to First

Amended Joint Plan of Collins & Aikman Corporation and its Debtor Subsidiaries (Exhibit F). Exhibit F purports to identify those leases that the Debtors will reject as of the effective date (the Effective Date) of their First Amended Joint Plan (the Plan). The Effective Date was October 12, 2007. The deadline for filing administrative claims arising from the rejection of leases under the Plan is November 12, 2007. 4. Exhibit F purports to identify at least twenty-nine of Relationals Equipment

Leases. However, the information listed on Exhibit F is insufficient to allow Relational to identify which Equipment Leases the Debtors intend to reject. In particular, Exhibit F does not list the schedule number of the Equipment Leases, in some cases fails to identify the date the Equipments Leases were executed, and does not list which equipment is subject to rejection. Additionally, Exhibit F identifies certain leases by and between Relationals Canadian affiliates and CACI, which filed for bankruptcy in Ontario, Canada. 5. Relational has engaged in discussions with the Debtors and Debtors counsel in an

effort to identify which leases the Debtors intend to reject. Although the Debtors have been able to identify certain of the leases, the Debtors have been unable to provide sufficient information to allow Relational to determine which Equipment Leases the Debtors have rejected or intend to reject. 6. Moreover, the Debtors appear not to have returned to Relational all of the

equipment subject to the purportedly rejected Equipment Leases.

7.

Additionally, the Debtors have informed Relational that the list of leases on

Exhibit F is incorrect, both as to which Equipment Leases the Debtors intend to reject and the dates which any Equipment Leases will be rejected. The Debtors have also been unable to explain why leases involving CACI are listed on Exhibit F. 8. As a result of the acknowledged inaccuracy of Exhibit F, Relational cannot

determine which, if any, Equipment Leases the Debtors intend to reject. In particular, Relational cannot determine whether the Debtors have rejected, or will reject any of Equipment Leases. Nor can Relational determine when rejection of any Equipment Leases may occur. 9. Out of an abundance of caution, Relational has filed the instant Claim in an

unliquidated amount to account for administrative obligations that will continue to accrue for unreturned equipment and unrejected Equipment Leases. 10. Additionally, this Claim is intended to serve as a reservation of Relationals rights

to assert an administrative claim based on any other damages arising from the Post-Petition Leases. 11. Relational reserves the right to amend or supplement this Claim to include

rejection damages on Post-Petition Leases it is currently unable to assess based on the incomplete information provided by the Debtors. 12. Once the Debtors are in a position to provide an exact list of which Equipment

Leases they have under the Plan and the respective dates of rejection, Relational will amend or supplement this Claim to, among other things, provide a liquidated claim amount. Relational intends to work cooperatively with the Debtors to resolve the outstanding issues surrounding the Equipment Leases.

WHEREFORE, Relational respectfully requests that the Court enter an order allowing the Claim in an amount to be determined, and granting Relational such other and further relief as may be just and necessary. Dated: November 12, 2007 Respectfully submitted

BY:

/s/ Michael Terrien Ronald R. Peterson Michael Terrien JENNER & BLOCK LLP 330 N. Wabash Ave. Chicago, IL 60611 PH: 312-923-8316 FAX: 312-923-8416 Attorneys for Relational, LLC et al.

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION, ) ) ) ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) Case No. 05-55932

COLLINS & AIKMAN PRODUCTS COMPANY, COLLINS & AIKMAN CANADA, INC., et al.,

Bankruptcy Judge Steven W. Rhodes

ORDER GRANTING AMENDED REQUEST FOR ALLOWANCE OF ADMINISTRATIVE CLAIM Upon the Amended Request for Allowance of Administrative Claim (the Motion)1 of Relational, LLC, Relational Funding Corporation, Relational Technology Services, and Relational Funding Canada Corporation (collectively, Relational); it appearing to the Court that notice of the hearing on the Motion was adequate, appropriate and in accordance with the Bankruptcy Code, 11 U.S.C. 101-1330 (the "Bankruptcy Code"), and the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules); the Court finding good cause to grant the relief sought in the; and the Court finding that (a) it has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334, and (b) this is a core proceeding pursuant to 28 U.S.C. 157 (b)(2); IT IS HEREBY ORDERED that 1. 2. The Motion is granted; Relational is hereby allowed (a) an unliquidated administrative claim against

CAPC under sections 503(b) and 507(a)(2) of the Bankruptcy Code for any post-petition administrative obligations that will arise as a result of unreturned equipment, unrejected
1

Capitalized terms used but not defined herein shall have the meanings ascribed in the Motion.

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Equipment Leases, or other damages arising from the Post-Petition Leases, and (b) an unliquidated administrative claim against CACI under sections 503(b) and 507(a)(2) of the Bankruptcy Code for any post-petition administrative obligations that will arise as a result of unreturned equipment, unrejected Equipment Leases, or other damages arising from the PostPetition Leases.

Dated __________, 2007

ENTER:

UNITED STATES BANKRUPTCY JUDGE

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