THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN (DETROIT) ) ) ) ) ) ) Chapter 11 Case No.

05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Hon. Steven W. Rhodes

In re: COLLINS & AIKMAN CORPORATION, et al., Debtors.

RESPONSE OF PRODUCTIVITY IMPROVEMENT CENTER, INC. CANADA AND PRODUCTIVITY IMPROVEMENT CENTER, INC. USA TO THE COLLINS & AIKMAN LITIGATION TRUSTS FIFTIETH OMNIBUS OBJECTION TO CLAIMS (INSUFFICIENT BOOKS AND RECORDS) Productivity Improvement Center, Inc. Canada and Productivity Improvement Center, Inc. USA (collectively hereinafter referred to as PIC), by and through its undersigned counsel, for its Response to The Collins & Aikman Litigation Trusts Fiftieth Omnibus Objection to Claims (Insufficient Books and Records) (the Claims Objection) states as follows: 1. 2. 3. 4. 5. PIC admits the allegations contained in Paragraph 1 of the Claims Objection. PIC admits the allegations contained in Paragraph 2 of the Claims Objection. PIC admits the allegations contained in Paragraph 3 of the Claims Objection. PIC admits the allegations contained in Paragraph 4 of the Claims Objection. PIC lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 5 of the Claims Objection and, therefore, denies the same. 6. PIC denies as untrue the allegations contained in Paragraph 6 of the Claims

Objection as those allegations relate to PIC. PIC lacks knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraph 6 of the Claims Objection and, therefore, denies the same.

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PIC lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 7 of the Claims Objection and, therefore, denies the same. 8. PIC lacks knowledge or information sufficient to for a belief as to the truth of the

allegations contained in Paragraph 8 of the Claims Objection and, therefore, denies the same.

AFFIRMATIVE DEFENSES 1. The Claims Objection fails to state a claim upon which relief may be granted and,

therefore, the Claims Objection should be dismissed. 2. The applicable doctrine of waiver, estoppel and laches effectively bar the Debtors

from obtaining the relief they are requesting in the Claims Objection insofar as those requests for relief relate to PIC. WHEREFORE, PIC respectfully requests that this Court enter an Order denying the relief requested in the Claims Objection and granting such other and further relief as may be just and proper under the circumstances. Respectfully submitted, WARNER NORCROSS & JUDD LLP

Date: July 21, 2008

BY:

/s/Dennis W. Loughlin DENNIS W. LOUGHLIN (P57084) Attorneys for Productivity Improvement Center, Inc. Canada and Productivity Improvement Center, Inc. USA 2000 Town Center, Suite 2700 Southfield, MI 48075 Phone: 248-784-5186 Fax: 248-603-9786 dloughlin@wnj.com

125953.125954 GR1566609-1

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