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

et al., Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) Honorable Steven W. Rhodes Debtors. / BROWN CORPORATION'S OBJECTION TO NOTICE OF RECLAMATION CLAIMS THE DEBTORS DEEM TO BE VALID NOW COMES Brown Corporation ("Brown") by and through its attorneys, Varnum, Riddering, Schmidt & Howlett LLP, and objects to the Notice of Reclamation Claims the Debtors Deem to be Valid (the "Notice") as follows: 1. On May 17, 2005, the Debtors' filed voluntary petitions for relief under Chapter

11 of the United States Bankruptcy Code and commenced the Debtors' cases (the "Petition Date"). 2. On or about May 20, 2005, the Debtors received Brown's demand letter in which

a reclamation claim was asserted against the Debtors in the amount of $1,464,042.24 (the "Initial Reclamation Demand"). Brown included a list of invoices with the Initial Reclamation Demand to substantiate its claim. 3. The Debtors have filed the Notice identifying the Inital Reclamation Demand

amount at $1,331,027.30 and reducing the Initial Reclamation Demand to $102,558.06. 4. According to the Notice, the Debtors reduced the Initial Reclamation Demand by

$440,708.17, claiming that such amount included goods which were either delivered before or after the 10-day reclamation period.

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Brown acknowledges that the Initial Reclamation Demand may have included

goods which were either delivered before or after the 10-day reclamation period. 6. After reducing the Initial Reclamation Demand by the amount of goods delivered

outside of the reclamation period, Brown has a reclamation claim of $888,785.72 (the "Amended Reclamation Claim"). Reclamation Claim. 7. The Debtors have not provided any evidence that the goods subject to the Initial Exhibit A is a list of all of the invoices subject to the Amended

Reclamation Demand were, in fact, delivered before or after the 10-day reclamation period, nor have they identified the invoices of the Initial Reclamation Demand to which the reduction corresponds. Thus, to the extent that the reduction of $440,708.17 consists of invoices listed in the Amended Reclamation Claim, the reduction should be denied. 8. The Debtors' also reduced the Initial Reclamation Demand by $784,511.22,

claiming that such amount represented goods that had been consumed by the date that the Initial Reclamation Demand was received by the Debtors. 9. The Debtors have not provided any evidence that the goods subject to the Initial

Reclamation Demand were, in fact, consumed prior to receiving the Initial Reclamation Demand nor have they identified the invoices of the Initial Reclamation Demand to which the reduction corresponds. Presumably, the Debtors have simply applied a uniform formula to all reclamation claims. 10. Until the Debtors provide evidence that Brown's goods were actually consumed

prior to the date of the Initial Reclamation Demand, the Debtors should not be able to categorically reduce the Initial Reclamation Demand or the Amended Reclamation Demand.

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The Debtors have also reduced the Initial Reclamation Demand by $3,249.85,

claiming that the Initial Reclamation Demand lacked sufficient information in time for the Debtors to identify goods and analyze the demand with respect thereto. 12. The Debtors have not provided any evidence to substantiate this reduction, nor

have they identified the invoices of the Initial Reclamation Demand to which the reduction corresponds. Thus, neither the Initial Reclamation Demand nor the Amended Reclamation Demand should be reduced by such amount. 13. Accordingly, the reductions to the Initial Reclamation Demand the Debtors seek

should be denied. WHEREFORE, Brown respectfully requests that the Court enter an order (i) striking the Debtors' Notice insofar as it invalidates any amount of Brown's reclamation claim; (ii) allowing Brown's reclamation claim in the amount of $888,785.72; and (iii) granting such other and further relief as is just. VARNUM, RIDDERING, SCHMIDT & HOWLETT LLP Attorneys for Brown Corporation Dated: September 23, 2005 /s/ Mary Kay Shaver Mary Kay Shaver (P-60411) Business Address: Bridgewater Place P.O. Box 352 Grand Rapids, MI 49501-0352 Telephone No.: (616) 336-6000 By:

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