Anda di halaman 1dari 600

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

FOURTH INTERIM FEE APPLICATION OF KIRKLAND & ELLIS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SERVICES RENDERED AS DEBTORS COUNSEL FOR THE PERIOD MAY 1, 2006 THROUGH AUGUST 31, 2006 Name of Applicant: Authorized to Provide Professional Services to: Date of Retention: Date of Entry of Order Authorizing Retention: Interim Fee Period for Which Compensation and Reimbursement is Sought: Amount of Compensation Requested: Kirkland & Ellis LLP Debtors May 17, 2005 Order Entered on May 26, 2005 [Docket No. 138] May 1, 2006 through August 31, 2006 $4,211,935.00

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 11405404.8

0W[;&*0

0555927061016000000000001

!g

Name of Applicant: Amount of Expense Reimbursement Requested: Total Compensation and Expense Reimbursement Requested: This Is: Blended Rate of Professionals (Including Paraprofessionals) Blended Rate of Professionals (Excluding Paraprofessionals)

Kirkland & Ellis LLP $180,891.37 $4,392,826.37 Fourth Interim Fee Application $432.34 $526.16

2
K&E 11405404.8

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

FOURTH INTERIM FEE APPLICATION OF KIRKLAND & ELLIS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SERVICES RENDERED AS DEBTORS COUNSEL FOR THE PERIOD MAY 1, 2006 THROUGH AUGUST 31, 2006 Kirkland & Ellis LLP (K&E), bankruptcy counsel for the above-captioned debtors (the Debtors), hereby applies (the Fourth Interim Fee Application) for entry of an order allowing it (a) fees in the amount of $4,211,935.00 for the reasonable and necessary legal services K&E has rendered to the Debtors and (b) the actual and necessary expenses that K&E incurred in the amount of $180,891.372 for the period from May 1, 2006 through August 31,

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. The total expenses requested reflect a deduction in the amount $457.60 for expenses included in the Monthly Fee Statements (as defined below) for which K&E is not seeking reimbursement.

K&E 11405404.8

2006 (the Interim Fee Period) pursuant to sections 330 and 331 of the Bankruptcy Code, 11 U.S.C. 101-1330 (the Bankruptcy Code), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), Rules 2016 -1 and 9014-1 of the Local Rules of the Bankruptcy Court for the Eastern District of Michigan (the Local Rules), the Retention Order (as defined below), the United States Trustee Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed under 11 U.S.C. 330

(the Trustee Guidelines) and the Administrative Order Establishing Procedures for Monthly Compensation and Reimbursement of Expenses for Professionals and Official Committee Members [Docket No. 290] (the Interim Compensation Order). In support of this

Fourth Interim Fee Application, K&E respectfully states as follows: Background 1. 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 Bankruptcy Rule 1015(b). 2. 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). 3. 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 Company, Inc., Nissan Motor Company Unlimited, Porsche Cars GB, Renault Crateur DAutomobiles, Toyota SA and Volkswagen AG.

2
K&E 11405404.8

Retention of and Continuing Disinterestedness of Kirkland & Ellis LLP 4. By this Courts order dated May 26, 2005, the Debtors were authorized to retain

K&E as their counsel, effective as of the Petition Date, with regard to the filing and prosecution of the chapter 11 cases and all related matters [Docket No. 138] (the Retention Order). The Retention Order authorizes the Debtors to compensate K&E at K&Es hourly rates charged for services of this type and to reimburse K&E for K&Es actual and necessary out-of-pocket expenses incurred, subject to application to this Court as set forth therein. The Retention Order is attached hereto as Exhibit A. 5. As disclosed in the Affidavit of Richard M. Cieri in Support of Application for an

Order Authorizing the Employment and Retention of Kirkland & Ellis LLP as Attorneys for the Debtors filed on May 17, 2005 (as supplemented by supplemental affidavits, the Affidavits), K&E does not hold or represent any interest adverse to the Debtors estate, and is a disinterested person as that term is defined in section 101(14) of the Bankruptcy Code, as modified by section 1107(b) of the Bankruptcy Code. 6. K&E may have in the past represented, may currently represent, and likely in the

future will represent parties-in-interest in connection with matters unrelated to the Debtors and the chapter 11 cases. K&E disclosed its connections to parties-in-interest that it has been able to ascertain using its reasonable efforts in the Affidavits. K&E has and will continue to update the Affidavits when necessary and as appropriate. 7. K&E performed the services for which it is seeking compensation on behalf of or

for the Debtors and their estates, and not on behalf of any committee, creditor or other entity. 8. Except to the extent of the advance payments paid to K&E that K&E previously

disclosed to this Court in the Affidavits, K&E has received no payment and no promises for

3
K&E 11405404.8

payment from any source other than the Debtors for services rendered or to be rendered in any capacity whatsoever in connection with the chapter 11 cases. 9. Pursuant to Bankruptcy Rule 2016(b), K&E has not shared, nor has K&E agreed

to share (a) any compensation it has received or may receive with another party or person other than with the partners, counsel and associates of K&E or (b) any compensation another person or party has received or may receive. 10. This is the fourth interim fee application that K&E has submitted in the chapter 11

cases. K&E has served monthly fee statements (collectively, the Monthly Fee Statements) on the United States trustee, counsel to the Committee, counsel to the prepetition secured lenders and counsel to the postpetition secured lenders for the following periods: a) b) c) d) 11. Monthly Fee Statement for the period May 1, 2006 through May 31, 2006; Monthly Fee Statement for the period June 1, 2006 through June 30, 2006; Monthly Fee Statement for the period July 1, 2006 through July 31, 2006; and Monthly Fee Statement for the period August 1, 2006 through August 31, 2006. The Monthly Fee Statement for May 2006 included a voluntary waiver of fees in

the amount of $23,320.00 and expenses in the amount of $6,624.02. The Monthly Fee Statement for June 2006 included a voluntary waiver of fees in the amount of $50,873.50 and expenses in the amount of $4,133.61. The Monthly Fee Statement for July 2006 included a voluntary waiver of fees in the amount of $19,609.50 and expenses in the amount of $4,798.19. The Monthly Fee Statement for August 2006 included a voluntary waiver of fees in the amount of $46,080.50 and expenses in the amount of $6,813.38. In total, the Monthly Fee Statements from May 1, 2006 through August 31, 2006 included a voluntary waiver of fees in the amount of $139,883.50 and expenses in the amount of $22,369.20 for a grand total of fees and expenses waived in the amount of $162,252.70 during the Interim Fee Period. Additionally, in preparing the Fourth

4
K&E 11405404.8

Interim Fee Application, K&E voluntarily agreed to waive an additional $457.60 in expenses that were originally requested in the Monthly Fee Statements. Accordingly, K&E has adjusted the total amount of reimbursement of expenses that it is requesting in the Fourth Interim Fee Application by this amount. 12. As of the date herein, K&E has received $2,561,055.71 from the Debtors for fees

and expenses incurred by K&E during the Interim Fee Period. This represents 80% of the fees and 100% of the expenses incurred and submitted by K&E for the May, June, and July 2006 Monthly Fee Statements. The objection deadline for the August 2006 Monthly Fee Statement expires on October 17, 2006. As of the date of this filing, K&E has not been paid any fees or expenses for the August 2006 Monthly Fee Statement. Previous Interim Fee Applications 13. On October 18, 2005, K&E filed the First Interim Fee Application of Kirkland &

Ellis LLP for Compensation and Reimbursement of Expenses for Services Rendered as Debtors Counsel for the Period May 17, 2005 through August 31, 2005 [Docket No. 1505] (the First Interim Fee Application). In the First Interim Fee Application, K&E sought compensation in the amount of $5,256,119.50 and reimbursement of expenses in the amount of $466,026.14. On November 18, 2005, the Court entered an order approving the First Interim Fee Application [Docket No. 1715]. 14. On February 24, 2006, K&E filed the Second Interim Fee Application of

Kirkland & Ellis LLP for Compensation and Reimbursement of Expenses for Services Rendered as Debtors Counsel for the Period September 1, 2005 through December 31, 2005 [Docket No. 2260] (the Second Interim Fee Application). In the Second Interim Fee

Application, K&E sought compensation in the amount of $4,888,277.50 and reimbursement of

5
K&E 11405404.8

expenses in the amount of $280,708.65. On March 22, 2006, the Court entered an order approving the Second Interim Fee Application [Docket No. 2452]. 15. On June 16, 2006, K&E filed the Third Interim Fee Application of

Kirkland & Ellis LLP for Compensation and Reimbursement of Expenses for Services Rendered as Debtors Counsel for the Period January 1, 2006 through April 30, 2006 [Docket No. 2856] (the Third Interim Fee Application). In the Third Interim Fee Application, K&E sought

compensation in the amount of $4,128,647.25 and reimbursement of expenses in the amount of $119,625.02. On July 14, 2006, the Court entered an order approving the

Third Interim Fee Application [Docket No. 3015]. Reasonable and Necessary Services Rendered by Kirkland & Ellis LLP Generally 16. K&E has advised and represented the Debtors in connection with the operation of

their businesses and all other matters arising in the performance of their duties as debtors and debtors in possession, except those matters for which the Debtors have retained the law firm of Carson Fischer P.L.C. or for which the Debtors have retained special counsel or ordinary course professionals. Furthermore, K&E has: (a) prepared various pleadings, motions and other papers; (b) submitted requests for relief and objections to other parties requests for relief to this Court for consideration; (c) appeared before this Court during hearings regarding the chapter 11 cases; and (d) has performed all of the other professional services that are described in this Fourth Interim Fee Application. 17. The rates described herein are K&Es hourly rates for services of this type

provided during the Interim Fee Period. Based on these rates and the services performed by each individual, the total reasonable value of such services rendered during the Interim Fee Period is $4,211,935.00. The K&E attorneys and paraprofessionals expended a total of 9,742.20 hours working on the chapter 11 cases during the Interim Fee Period. In accordance with the factors

6
K&E 11405404.8

enumerated in Section 330 of the Bankruptcy Code, the amount of fees requested is fair and reasonable given: (a) the complexity of the chapter 11 cases; (b) the time expended; (c) the nature and extent of the services rendered; (d) the value of such services; and (e) the costs of comparable services other than in a case under the Bankruptcy Code. See, e.g., In re Moss, 320 B.R. 143, 156-57 (Bankr. E.D. Mich. 2005); In re Ray, 314 B.R. 643, 662-63 (Bankr. M.D. Tenn. 2004); In re Chary, 201 B.R. 783, 787-88 (Bankr. W.D. Tenn. 1996). 18. The attached Exhibit B provides a summary statement of the number of hours of

service rendered by each attorney and paraprofessional and the hourly rate of each individual by Subject Matter (as defined below) during the Interim Fee Period. 19. The attached Exhibit C: (a) identifies the attorneys and paraprofessionals who

rendered services in each Subject Matter; (b) describes each activity or service that each individual performed; and (c) states the number of hours (in increments of one-tenth of an hour) spent by each individual providing the services. The information in each invoice in the attached Exhibit C corresponds to the matter number that K&E assigned to the Subject Matters. If a Subject Matter does not appear, K&E did not bill time or expenses for that Subject Matter during the Interim Fee Period, but may bill time for that Subject Matter in the future. 20. Local Rule 2016 requires law firms to include biographical information for The attached Exhibit D includes brief

attorneys billing fees during a chapter 11 case.

biographical profiles of K&E attorneys who billed at least 50 hours of time during the Interim Fee Period. Biographical information about attorneys who billed less than 50 hours during the Interim Fee Period is available upon request.

7
K&E 11405404.8

Reasonable and Necessary Services Rendered by Kirkland & Ellis LLP Categorized by Subject Matter 21. The professional services that K&E rendered during the Interim Fee Period are

grouped into the numbered and titled categories of the subject matters described in paragraphs 22 through 50 herein (each, a Subject Matter). 22. Matter 3 Adversary Proceedings and Contested Matters (Fees: $383,452.00; Expenses: $16,676.24; Hours: 761.60) This Subject Matter includes time spent addressing various adversary proceedings and contested matters filed in the chapter 11 cases. More specifically, this Subject Matter includes time spent: (a) responding to numerous formal and informal discovery requests from General Electric Capital Corporation (GECC); (b) prosecuting the Debtors complaint to recover estate assets from Northern Trust and the related beneficiaries motion to intervene and counterclaims; (c) preparing for the GECC recharacterization trial, including preparing exhibits, witnesses, affidavits and drafting and filing related pleadings; (d) addressing GECCs action against Collins & Aikman Automotive Hermosillo, S.A. de C.V.; (e) researching and analyzing a potential complaint for a customers breach of contract; (f) researching and litigating the Committees motions to conduct 2004 examinations of certain of the Debtors customers; and (g) addressing various issues arising in the numerous adversary actions filed in connection with the Debtors bankruptcy cases. 23. Matter 5 Asset Analysis (Fees: $229,352.50; Expenses: $879.46; Hours: 548.70) This Subject Matter includes time spent: (a) analyzing real and personal property leases and interests to determine if they remain beneficial to the Debtors and their estates; (b) corresponding with the Debtors and their advisors regarding the sale of certain assets and

8
K&E 11405404.8

business divisions; (c) preparing and serving notices of sale and abandonment of de minimis assets; (d) negotiating and seeking approval of asset purchase agreements for the sale of numerous assets, including, but not limited to, assets located at the Debtors Williamston facility, the Debtors El Paso, Texas facility, and one of the Debtors Roxboro, North Carolina facilities; (e) prosecuting the Debtors Motion for an Order Authorizing the Wind-Down of Their Fabrics Business and Certain Related Actions in Connection Therewith [Docket No. 2746] and counseling the Debtors with respect to the wind-down; (f) analyzing the potential recovery of estate assets from a trust held by Wachovia Bank and Trust Company, N.A.; and (g) drafting and seeking approval of the Debtors Motion for an Order Approving Procedures for the Sale of Certain Assets [Docket No. 3319]. 24. Matter 6 Business Operations (Fees: $393,536.50; Expenses: $4,589.65; Hours: 775.10) This Subject Matter involves time spent advising the Debtors regarding business operations, including: (a) addressing vendor and customer issues; (b) identifying and responding to a variety of tooling and lien issues; (c) strategizing with the Debtors management team and advisors regarding priorities and processes to ensure uninterrupted operations; (d) addressing numerous customer and vendor-related issues; (e) preparing for and attending the meetings of the Board of Directors of Collins & Aikman Corporation; (f) reviewing and analyzing various aspects of the Debtors business plan; (g) preparing for and attending various meetings related to pricing relief on customer contracts and potential sales of various assets; (h) drafting and negotiating various revised customer agreements; and (i) assembling and coordinating the due diligence process with respect to sale of estate assets.

9
K&E 11405404.8

25.

Matter 7 Case Administration (Fees: $223,245.00; Expenses: $25,172.22; Hours: 1,170.00) This Subject Matter describes administrative activities, including: (a) managing

and coordinating the chapter 11 cases; (b) complying with applicable service and notice requirements; (c) assisting the Debtors in fulfilling various duties as debtors and debtors in possession; and (d) complying with the requirements of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, this Courts orders and other applicable law. 26. Matter 8 Cash Collateral/DIP Financing (Fees: $73,847.50; Expenses: 1,818.29; Hours: 167.90) This Subject Matter describes K&E activities performed to help the Debtors comply with their obligations under the debtor-in-possession financing agreements. As a result of the Debtors financial condition in the period before and since the Petition Date, the Debtors had to obtain debtor-in-possession financing from multiple lenders pursuant to three separate debtor-in-possession financing arrangements (collectively, the DIP Financing Facilities). The Subject Matter includes time K&E spent: (a) counseling the Debtors and preparing documents with respect to the Debtors reporting obligations under the DIP Financing Facilities; (b) counseling the Debtors with respect to compliance under the DIP Financing Facilities; (c) negotiating, drafting and prosecuting the Motion for an Order Authorizing the Debtors to Enter into the Fourth Amendment to and Consent under Debtor In Possession Financing Agreement [Docket No. 2902]; and (d) negotiating, drafting and prosecuting the Debtors Motion to Modify Certain Adequate Protection Obligations Payable to Their Senior, Secured Prepetition Lenders [Docket No. 3183].

10
K&E 11405404.8

27.

Matter 9 Claims Administration and Objections (Fees: $92,281.50; Expenses: $1,739.13; Hours: 213.70) This Subject Matter includes time spent: (a) identifying and evaluating claims

against the Debtors; (b) developing and implementing strategies to address such claims; (c) drafting presentations on claims estimates with respect to the formation of a plan of reorganization; (d) analyzing certain tort claims; (e) drafting stipulations resolving claims against the Debtors; and (f) drafting and filing the Debtors Objection to Motion of ACT Laboratories, Inc. for Entry of an Order Deeming Proof of Claim Timely Filed [Docket No. 3175]. 28. Matter 11 Executory Contracts and Unexpired Leases (Fees: $402,766.00; Expenses: $3,970.47; Hours: 892.20) This Subject Matter describes legal services provided to the Debtors relating to their numerous executory contracts and unexpired leases, including: (a) advising the Debtors with respect to the contemplated assumption, rejection or termination of their executory contracts and unexpired leases; (b) preparing and filing motions to reject certain executory contracts and unexpired leases and drafting affidavits in support thereof; (c) drafting the notice of appeal and brief in support of the Debtors appeal of the Order Pursuant to Section 365(d)(3) of the Bankruptcy Code Compelling Payment of Unpaid Taxes Due Post-Petition Under a Non-Residential Real Property Lease [Docket No. 2662]; (d) negotiating and settling disputes with counterparties to myriad executory contracts and unexpired leases; (e) negotiating with GECC to resolve certain disputes related to the recharacterization of certain of the Debtors leases; (f) preparing and prosecuting the Debtors Motion for Entry of an Order Authorizing the Debtors to Reject Certain Unexpired Leases [Docket No. 2838]; (g) defending against motions to compel performance under certain of the Debtors executory contracts and unexpired leases; and

11
K&E 11405404.8

(h) drafting and filing the Debtors Motion for an Order Approving Expedited Rejection Procedures for Executory Contracts and Unexpired Leases [Docket No 3071]. 29. Matter 12 Hearings (Fees: $189,872.00; Expenses: $16,016.55; Hours: 521.60) This Subject Matter includes time spent by K&E preparing for and attending various court hearings during the Interim Fee Period. During the Interim Fee Period, there were at least six separate hearings at which K&E appeared, including one hearing during May, two hearings during June, one hearing during July and two hearings during August. At certain of these hearings, K&E presented offers of direct examination in support of the relief requested by the Debtors. Additionally, this Subject Matter also includes time spent monitoring docket activity and preparing and filing documents in support of the hearings, including agendas and amended agendas for each omnibus hearing. 30. Matter 13 Fee/Retention Application/Objections (K&E) (Fees: $85,343.00; Expenses: $3,341.55; Hours: 279.00) This Subject Matter describes K&E services performed in connection with the preparation of K&Es Monthly Fee Statements pursuant to the procedures and standards set forth in the Interim Compensation Order, the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, the Trustee Guidelines and other applicable law. This Subject Matter also includes time spent: (a) performing a review of conflicts in accordance with applicable law; (b) preparing and filing the Fifth Supplemental Affidavit of Richard M. Cieri in Support of the Debtors Application for an Order Authorizing the Employment of Kirkland & Ellis LLP as Attorneys for the Debtors [Docket No. 2868] (c) preparing and filing the Third Interim Fee Application of Kirkland & Ellis LLP for Compensation and Reimbursement of Expenses for Services for the

12
K&E 11405404.8

Period January 1, 2006 through April 30, 2006 [Docket No. Docket No. 2856]; (d) preparing and distributing K&Es Monthly Fee Statements; and (e) preparing and filing certificates of no objection to K&Es Monthly Fee Statements. 31. Matter 16 Fee/Retention Application/Objections (Other Professionals) (Fees: $88,658.50; Expenses: $668.18; Hours: 297.10) This Subject Matter includes time spent preparing the following applications and negotiating the relevant agreements with respect thereto: (a) the Debtors Supplemental

Application Authorizing the Debtors to Expand the Scope of Their Retention of Deloitee Tax LLP Nunc Pro Tunc to May 16, 2006 [Docket No. 2910], the Debtors Application for Order Authorizing the Employment and Retention of Haley & Aldrich, Inc. as an Environmental Consultant [Docket No. 2936] and the Debtors Application for Order Authorizing the Employment and Retention of Gordon Brothers Industrial, LLC and Tex-Mach, Inc. as Sales Consultant for the Sale of Residual Assets [Docket No. 3118]; (b) a notice of an amended engagement letter with Gordon Brothers Industrial, LLC. and Tex-Mach, Inc. [Docket No. 3243] (c) statements of fees and expenses for ordinary course professionals; (d) supplemental affidavits of disinterestedness and fee applications of certain professionals retained by the Debtors. 32. Matter 17 Disclosure Statement and Plan of Reorganization (Fees: $655,329.50; Expenses: $5,886.28; Hours: 1,254.10) This Subject Matter includes time spent: (a) preparing, filing and prosecuting (i) the Debtors Fourth Motion for an Order Extending the Exclusivity Periods to File a Chapter 11 Plan and to Solicit Votes Thereon [Docket No. 2900] and (ii) the Debtors Fifth Motion for an Order Extending the Exclusivity Periods to File a Chapter 11 Plan and to Solicit Votes Thereon [Docket No. 3302]; (b) preparing and filing (i) the Joint Plan of Reorganization of

13
K&E 11405404.8

Collins & Aikman Corporation and Its Subsidiary Debtors [Docket No. 3234] and (ii) the Debtors Disclosure Statement for the Joint Plan of Reorganization of Collins & Aikman Corporation and Its Subsidiary Debtors [Docket No. 3233]; (c) planning strategy and tactics related to the preparation and confirmation of a plan of reorganization; and (d) researching and analyzing numerous issues with respect to treatment of creditors and parties in interest under a plan of reorganization. 33. Matter 18 Reclamation (Fees: $11,946.50; Expenses: $203.72; Hours: 31.10) This Subject Matter includes time spent by K&E: (a) analyzing reclamation demands; (b) collaborating with the Debtors to resolve such demands; (c) communicating with the suppliers that submitted the reclamation demands; and (d) engaging in research with respect to the reclamation demands. 34. Matter 19 Relief from Automatic Stay (Fees: $23,922.00; Expenses: $215.65; Hours: 49.90) This Subject Matter includes time spent: (a) preparing for a hearing regarding extending the automatic stay to litigation affecting certain former and current directors and officers; (b) analyzing issues with respect to a motion for relief from the automatic stay to exercise setoff rights filed by Johnson Controls, Inc.; and (c) preparing and drafting stipulations granting limited relief from the automatic stay to certain parties. 35. Matter 21 Tax Issues (Fees: $33,601.50; Expenses: $255.94; Hours: 62.50) This Subject Matter describes services performed by K&E to analyze tax issues related to the chapter 11 cases, including: (a) providing advice and corresponding with the

14
K&E 11405404.8

Debtors regarding payment of certain real and personal property taxes; (b) evaluating tax consequences of distributions to creditors proposed under the Debtors plan of reorganization; and (c) analyzing several issues surrounding tax liabilities. 36. Matter 22 Travel (Fees: $128,339.00; Expenses: $82,096.97; Hours: 239.50) This Subject Matter includes time spent by K&E professionals traveling while representing the Debtors. K&E billed the Debtors for one-half of the total time that K&E professionals spent for non-working travel. 37. Matter 23 Utilities (Fees: $5,328.00; Expenses: $0.00; Hours: 11.10) This Subject Matter involves time spent responding to issues involving utilities. 38. Matter 24 Environmental (Fees: $18,767.00; Expenses: $39.27; Hours: 31.80) This Subject Matter includes time spent analyzing various environmental issues arising from the Debtors operations at their various facilities. Included in this Subject Matter is time related to: (a) advising the Debtors of strategies with respect to honoring their

environmental obligations while in bankruptcy; (b) counseling the Debtors regarding federal and state requirements as owners, operators and lessees of real property; and (c) analyzing and advising the Debtors with respect to various environmental claims filed against the Debtors and litigation related thereto.

15
K&E 11405404.8

39.

Matter 25 International (Fees: $175,033.50; Expenses: $2,512.77; Hours: 348.10) This Subject Matter includes time spent: (a) overseeing the consolidated

administration of the Debtors European subsidiaries in the English High Court in London (the UK Proceedings); (b) attending meetings with the administrators and creditor bodies in the UK Proceedings, as well as the Debtors major creditor constituencies, regarding numerous issues involving the UK Proceedings; (c) analyzing various cross-border insolvency issues; and (d) preparing claims to be filed in the UK Proceedings. 40. Matter 26 Labor and Employee Benefits (Fees: $611,072.50; Expenses: $10,950.68; Hours: 1,292.30) This Subject Matter includes legal services related to general labor and employee issues. In particular, this Subject Matter includes time spent performing the following tasks and counseling the Debtors with respect to: (a) engaging in weekly status conferences with the Debtors and its advisors regarding labor and employment issues; (b) researching and analyzing state and federal wage laws; (c) analyzing the Debtors other post-employment benefits and the Debtors alternatives with respect thereto; (d) analyzing the Debtors severance and WARN Act payment obligations to current and former employees; (e) reviewing and analyzing the Debtors pension plans, including analyzing the impact of recent pension reform and different alternatives and preparing relevant tax forms with respect thereto; (f) reviewing and analyzing the Debtors collective bargaining agreements, compiling documents for a data room to be accessed by certain of the Debtors unions, strategizing and otherwise preparing for union negotiations; (g) analyzing the effect of sales of assets and plan of reorganization alternatives on the Debtors labor and employment situation; (h) reviewing and analyzing the Debtors qualified and non-qualified

16
K&E 11405404.8

benefit plans, including retiree benefit plans and certain rabbi trust agreements entered into by the Debtors before the Petition Date; (i) researching and analyzing various issues related to ERISA and COBRA; and (j) complying with the first day wage order [Docket No. 48]. 41. Matter 27 Avoidance Actions (Fees: $52,136.50; Expenses: $1,480.69; Hours: 121.20) This Subject Matter describes legal services related to the investigation and review of historical transactions and the examination of potential avoidance actions for recovery of estate property. 42. Matter 28 Corporate and Securities Matters (Fees: $85,368.00; Expenses: $1,198.90; Hours: 155.20) This Subject Matter describes legal advice provided to the Debtors on all matters relating to general corporate and securities issues, including corporate governance, fiduciary duties, Securities and Exchange Commission (SEC) reporting obligations and general operational issues. This Subject Matter includes time spent: (a) drafting and filing various notices and reports with the SEC; (b) drafting and revising various term sheets and asset purchase agreements with respect to the potential disposition of various assets of the Debtors businesses; (c) drafting and revising numerous confidentiality agreements relating to asset sales; and (d) preparing for and attending meetings of the Board of Directors of Collins & Aikman Corporation. 43. Matter 29 Stakeholder Communications (Fees: $67,493.50; Expenses: $9.20; Hours: 104.50) This Subject Matter includes time: (a) responding to numerous telephone calls and written correspondence from various creditors; (b) responding to inquiries by the Committee

17
K&E 11405404.8

and the agents for the prepetition and postpetition secured lenders; and (c) preparing for and attending meetings and conferences with the Committee and the agents for the prepetition and postpetition secured lenders. 44. Matter 34 Insurance (Fees: $30,999.50; Expenses: $462.58; Hours: 73.90) This Subject Matter includes legal services rendered by K&E related to the Debtors rights and obligations related to insurance, including time spent preparing, filing and prosecuting the Debtors Motion for an Order Approving the Settlement Agreement with OneBeacon America Insurance Company and National Indemnity Company [Docket No. 2896] and researching case law related thereto. 45. Matter 35 Intellectual Property (Fees: $74,422.50; Expenses: $438.42; Hours: 174.00) This Subject Matter includes time spent analyzing various intellectual property issues arising from the Debtors operations. Included in this Subject Matter is time related to: (a) advising the Debtors of strategies with respect to their intellectual property in the bankruptcy context; (b) analyzing the Debtors intellectual property with respect to their European affiliates; (c) prosecuting the Debtors intellectual property rights with respect to the Karmann Wilhelm adversary proceeding and arbitration; and (d) negotiating and drafting various agreements related to the transfer of foreign intellectual property.

18
K&E 11405404.8

46.

Matter 37 Shareholder Litigation (Fees: $757.50; Expenses: $0.00; Hours: 1.50) This Subject Matter includes time spent analyzing the transfer of certain securities

litigation filed against the Debtors and the Debtors current and former directors and officers to the Eastern District of Michigan. 47. Matter 39 Liens (Fees: $20,458.00; Expenses: $225.96; Hours: 47.90) This Subject Matter describes K&E services performed in reviewing, analyzing and otherwise responding to various issues involving alleged liens and security interests on and in the Debtors assets. 48. Matter 40 Vendor/Supplier Matters (Fees: $47,158.00; Expenses: $29.85; Hours: 96.80) This Subject Matter includes legal services related to issues and disputes involving the Debtors vendors and suppliers, including the negotiation and drafting of a master sales agreement. 49. Matter 41 Document Subpoena Investigation (Fees: $2,161.50; Expenses: $1.85; Hours: 5.10) This Subject Matter includes time spent addressing the ongoing governmental investigations into certain alleged prepetition activities of the Debtors and responding to document subpoenas with respect thereto.

19
K&E 11405404.8

50.

Matter 42 Termination of Joint Venture (Fees: $5,286.00; Expenses: $10.90; Hours: 14.80) This Subject Matter includes time spent negotiating the sale of the Debtors

interest in Collins & Aikman MOBIS, LLC. Actual and Necessary Expenses 51. Attached hereto as Exhibit E is a summary of the expenses incurred during the

Interim Fee Period for which reimbursement is sought. These disbursements comprise the requested sum for K&Es out-of-pocket expenses, totaling $180,891.37. 52. It is K&Es policy to charge its clients in all areas of practice the amounts

incurred by K&E for identifiable, non-overhead expenses incurred in connection with the representation of the relevant client that would not have been incurred except for representation of that particular client. Examples of such expenses are postage, overnight mail, courier

delivery, computer-assisted legal research, photocopying, printing, out-going facsimile transmissions, airfare and lodging. 53. K&E charges between $0.10 and $0.20 per page for duplication based on office

location and $0.75 per page for outgoing telecopier transmissions (plus related toll charges). K&E does not charge its clients for incoming telecopier transmissions. K&E has negotiated a discounted rate for Westlaw computer assisted legal research, which is approximately $125 per hour of online use of the standard Westlaw databases. Representations 54. This is K&Es fourth interim fee application pursuant to the Interim

Compensation Order, covering the period from May 1, 2006 through August 31, 2006. Although every effort has been made to include all fees and expenses from the Interim Fee Period in this Fourth Interim Fee Application, some fees and expenses might not be included due to delays

20
K&E 11405404.8

caused by accounting and processing procedures. K&E reserves the right to make further application to the Court for allowance of fees and expenses not included herein. As to fees and expenses incurred after August 31, 2006, K&E will include such amounts in future monthly fee statements and interim fee applications. 55. Application The total time spent by K&E during the period covered by this Fourth Interim Fee was 9,742.20 hours, including 7,210.20 attorney hours and 2,532.00

paraprofessional hours, which represents fees of $4,211,935.00. The average hourly rate for the services rendered is $432.34. The average hourly rate for time spent by attorneys is $526.16. K&E has incurred out-of-pocket expenses in the amount of $180,891.37 and requests reimbursement thereof. A summary of out-of-pocket expenses and an itemized list of each disbursement made are attached within Exhibit E. 56. In summary, by this Fourth Interim Fee Application, K&E requests allowance and

payment of any outstanding amounts of fees and expenses in the total amount of $4,392,826.37 consisting of: (a) $4,211,935.00 for the actual, reasonable and necessary professional services rendered by K&E on behalf of the Debtors (representing 100% of fees for services rendered, including the 20% previously held back pursuant to the Interim Compensation Order); and (b) $180,891.37 for actual and necessary costs and expenses. K&E has explained to the Office of the United States Trustee that it is requesting approval for payment of 100% of fees (including the 20% held back). The Office of the United States Trustee has no objection and pointed K&E to certain cases in the Eastern District of Michigan where this procedure was followed. Moreover, as K&E continues to represent the Debtors throughout the chapter 11 cases, there will continue to be certain earned fees for which K&E has not been paid, including fees for which a monthly fee statement has not been submitted and for the 20% holdback for those monthly fee

21
K&E 11405404.8

statements for which an interim fee application has not been submitted or is still subject to objection. At the time of filing the Fourth Interim Fee Application, K&E had not been paid any fees or expenses for August 2006. Accordingly, the estates will remain protected should the Court grant K&Es request for payment of the holdback. WHEREFORE, K&E respectfully requests the entry of an order (a) allowing an administrative expense claim for K&E compensation and reimbursement for its fees and expenses incurred during the Interim Fee Period, (b) authorizing and directing payment of such amounts and (c) granting such other and further relief as is just and proper. Dated: October 16, 2006 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

Counsel for the Debtors

22
K&E 11405404.8

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 FOURTH INTERIM FEE APPLICATION OF KIRKLAND & ELLIS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SERVICES RENDERED AS COUNSEL FOR THE DEBTORS FOR THE PERIOD MAY 1, 2006 THROUGH AUGUST 31, 2006 PLEASE TAKE NOTICE THAT Kirkland & Ellis LLP (K&E) has filed the Fourth Interim Fee Application of Kirkland & Ellis LLP for Compensation and Reimbursement of Expenses for Services Rendered as Counsel for the Debtors for the Period May 1, 2006 through August 31, 2006 (the Fourth Interim Fee Application) pursuant to the Administrative Order Establishing Procedures for Monthly Compensation and Reimbursement of Expenses for

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 11407681.3

Professionals and Official Committee Members dated June 9, 2005 [Docket No. 290] (the Compensation Procedures Order). PLEASE TAKE FURTHER NOTICE THAT your rights may be affected. You may wish to review the Fourth Interim Fee Application and discuss it with your attorney, if you have one in these cases. (If you do not have an attorney you may wish to consult one.) PLEASE TAKE FURTHER NOTICE THAT in accordance with the Compensation Procedures Order, if you wish to object to the Court granting the relief sought in the Application, or if you want the Court to otherwise consider your views on the Application, no later than November 6, 2006 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.

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

2
K&E 11407681.3

PLEASE TAKE FURTHER NOTICE THAT you must also serve the documents so that they are received on or before November 6, 2006 at 4:00 p.m. prevailing Eastern Time, in accordance with the Compensation Procedures Order, including to: Kirkland & Ellis LLP Attn: Richard M. Cieri Citigroup Center 153 East 53rd Street New York, New York 10022 Facsimile: (212) 446-4900 E-mail: rcieri@kirkland.com -andKirkland & Ellis LLP Attn: David L. Eaton Ray C. Schrock Marc J. Carmel 200 East Randolph Drive Chicago, Illinois 60601 Facsimile: (312) 861-2200 E-mail: deaton@kirkland.com rschrock@kirkland.com mcarmel@kirkland.com -andCarson Fischer, P.L.C. Attn: Joseph M. Fischer 4111 West Andover Road West - Second Floor Bloomfield Hills, Michigan 48302 Facsimile: (248) 644-1832 E-mail: jfischer@carsonfischer.com PLEASE TAKE FURTHER NOTICE THAT if no responses to the Application are timely filed and served, the Court may grant the Application and enter the order without a hearing as set forth in Rule 2016-3 of the Local Rules for the United States Bankruptcy Court for the Eastern District of Michigan.

3
K&E 11407681.3

Dated: October 16, 2006

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) 4111 West Andover Road West - Second Floor Bloomfield Hills, Michigan 48302 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

4
K&E 11407681.3

CERTIFICATE OF SERVICE I, Marc J. Carmel, an attorney, certify that on or before the 17th day of October, 2006, I will cause to be served, by e-mail and by overnight delivery, in the manner and to the parties set forth on the attached service lists, a true and correct copy of the foregoing Fourth Interim Fee Application of Kirkland & Ellis LLP for Compensation and Reimbursement of Expenses for Services Rendered as Debtors Counsel for the Period May 1, 2006 through August 31, 2006. Dated: October 16, 2006 /s/ Marc J. Carmel Marc J. Carmel

K&E 11407717.3

Served via Electronic Mail

CREDITOR NAME A Freeman Acord Inc Adrian City Hall Alice B Eaton Athens City Tax Collector Basell USA Inc Brendan G Best Bryan Clay Champaign County Collector Chris Kocinski City Of Eunice City Of Evart City Of Kitchener Finance Dept City Of Lowell City Of Marshall City Of Muskegon City Of Port Huron City Of Rialto City Of Rochester Hills City Of Salisbury City Of Westland City Of Woonsocket Ri City Treasurer City Treasurer DaimlerChrysler DaimlerChrysler Daniella Saltz Danielle Kemp David H Freedman David Heller David Youngman DuPont Earle I Erman Erin M Casey Frank Gorman Gail Perry Ge Capital GE Polymerland George E Schulman Gold Lange & Majoros PC Hal Novikoff Heather Sullivan James A Plemmons Jim Clough Joe LaFleur Joe Saad John A Harris John Green John J Dawson John S Sawyer Josef Athanas Joseph Delehant Esq Joseph M Fischer Esq K Crumbo K Schultz Kim Stagg Kimberly Davis Rodriguez Leigh Walzer Levine Fricke Inc M Crosby Macomb Intermediate School Marc J Carmel Mark Fischer

CREDITOR NOTICE NAME John Livingston John Fabor Mike Keith Scott Salerni

Barb Neal The Mayor at City Hall Roger Elkins City Manager Pauline Houston Lowell Regional Wastewater Maurice S Evans City Manager Derrick Smith Treasurer's Office City Treasurer Kurt A Dawson City Assesor Treasurer Business License Div Pretreatment Division Tracy Horvarter

Bruce Tobiansky

Val Venable

Stuart A Gold & Donna J Lehl

EMAIL afreeman@akingump.com jlivingston@acordinc.com cityofadrian@iw.net aeaton@stblaw.com finance@cityofathens.com scott.salerni@basell.com bbest@dykema.com bryan_clay@ham.honda.com bneal@co.champaign.il.us christopher.j.kocinski@bofasecurities.com Eunicela@hotmail.com evartmanager@sbcglobal.net finance@city.kitchener.on.ca MYoung@ci.lowell.ma.us Mevans@cityofmarshall.com derrick.smith@postman.org cphdp@porthuron.org treasurer@rialtoca.gov treasury@rochesterhills.org finwebreq@salisburync.gov finance@ci.westland.mi.us webmaster@woonsocketri.org THovarter@cityofmarshall.com Ncowdrey@corunna-mi.gov kpm3@daimlerchrysler.com krk4@daimlerchrysler.com dsaltz@ford.com danielle.kemp@lw.com dfreedman@ermanteicher.com david.heller@lw.com David.Youngman@ColAik.com bruce.d.tobiansky@usa.dupont.com eerman@ermanteicher.com ecasey@stblaw.com fgorman@honigman.com perry.gail@pbgc.com rail.sales@ge.com valerie.venable@ge.com ges@dgdk.com sgold@glmpc.com dlehl@glmpc.com HSNovikoff@wlrk.com hsullivan@unumprovident.com jplemmons@dickinson-wright.com jrc8@daimlerchrysler.com joe_lafleur@ham.honda.com js284477@bloomberg.net jharris@quarles.com greenj@millercanfield.com jdawson@quarles.com jss@sawyerglancy.com josef.athanas@lw.com joseph.delehant@sylvania.com jfischer@carsonfischer.com kcrumbo@kraftscpas.com kschultz@tmmna.com kim.stagg@nmm.nissan-usa.com Kimberly.Rodriguez@gt.com lwalzer@angelogordon.com veronica.fennie@lfr.com mcrosby@akingump.com webmaster@misd.net mcarmel@kirkland.com mark.w.fischer@gm.com

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 1 of 2

Served via Electronic Mail

CREDITOR NAME Michael R Paslay Michael Stamer Michigan Department Of Treasury Mike O'Rourke Mike Paslay Ministry Of Finance Corp Tax Branch Missouri Dept Of Revenue Municipalite Du Village De Nick Shah Nina Rosete Paul Hoffman Pension Benefit Guaranty Corporation Pension Benefit Guaranty Corporation Peter Schmidt Peter V Pantaleo Phh Canada Inc Philip Dublin Phoenix Contracting Company R Aurand R J Sidman Ralph E McDowell Ray C Schrock Rick Feinstein Ricoh Canada Inc Robert J Diehl Jr Robert Weiss Ronald A Leggett Ronald R Rose Sarah Eagle Sean P Corcoran Sheryl Toby Stark County Treasurer State Of Michigan

CREDITOR NOTICE NAME

15663507 Lacolle

Sara Eagle & Gail Perry Sara Eagle & Gail Perry

Tricia Sommers

Collector Of Revenue

State Of Michigan State Of Michigan Stephen E Spence Stephen S LaPlante T Pryce Tax Administrator Thomas Radom Treasurer Of State Tricia Sherick Tyco Capital Inc United Rentals Of Canada Inc Ville De Farnham Voridian Canada Company William C Andrews William G Diehl William J Byrne

PA Powers Michigan Dept Of Environmental Quality Environmental Assistance Div Michigan Dept Of Treasury Collection Div Office of Financial Mgmt Cashiers Office Michigan Unemployment Insurance Agency US Trustee

EMAIL mpaslay@wallerlaw.com mstamer@akingump.com treasReg@michigan.gov Michael.Orourke@colaik.com mike.paslay@wallerlaw.com info@electionsquebec.qc.ca mied@dor.mo.gov maire@st-zotique.com Nick.Shah@cit.com nina.m.rosete@bofasecurities.com phoffman@bofasecurities.com eagle.sara@pbgc.gov efile@pbgc.gov pschmidt@dykema.com ppantaleo@stblaw.com phhmail@phhpc.com pdublin@akingump.com triciawinkle@hotmail.com raurand@e-bbk.com rjsidman@vssp.com rmcdowell@bodmanllp.com rschrock@kirkland.com rick.feinstein@ubs.com legal@ricoh.ca rdiehl@bodmanllp.com rweiss@honigman.com leggettr@stlouiscity.com rrose@dykema.com eagle.sarah@pbgc.com sean.p.corcoran@delphi.com stoby@dykema.com PAPowers@co.stark.oh.us deq-ead-env-assist@michigan.gov

Jim Cambio Joseph T. Deters

Service de la Tresorerie

treasReg@michigan.gov shuttkimberlyj@michigan.gov steve.e.spence@usdoj.gov laplante@millercanfield.com tpryce@ford.com jcambio@tax.ri.gov radom@butzel.com treasurer@tos.state.oh.us tsherick@honigman.com Frank.Chaffiotte@cit.com e-rental@ur.com msaintdenis@ville.farnham.qc.ca blanderson@eastman.com kandrews@e-bbk.com wdiehl@e-bbk.com bbyrne@e-bbk.com

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 2 of 2

Served via Overnight Mail

CREDITOR NOTICE NAME Rob Morgan Michael S Stamer Philip C Dublin

ADDRESS2

COUNTRY

Mike Keith Charlie Burrill Linda Vesci Mary Callahan Roxane Ellwalleger Mark Ferderber Thomas B Radom Attn Receiver General International Tax Service PO Box 190 PO Box 1717 Utilities Department Income Tax Division Income Tax Division Canton Income Tax Dept Wastewater Labroratory

Canada Canada

Mary Ellen Hinckle Water Utilities Dept Of Building And Safety City Attorneys Office Tax Department Water Department James P Bulhinger City Treasurer

File 54563

PO Box 8099

PO Box 1057

Port Huron Police Department Don Brown Barbara J Walker Stacy Fox Jeff Rutter David Brasseur Susan F Herr Ronald Rose & Brendan Best Todd McCallum Gary Torke Law Dept William Stiefel 1084 Doris Rd 47690 E Anchor Ct

CREDITOR NAME Advanced Composites Inc Akin Gump Strauss Hauer & Feld LLP American General Finance Assoc Receivables Funding Inc Athens City Tax Collector Basf Corporation Bayer Material Sciences BNY Midwest Trust Company BNY Midwest Trust Company Brown Corporation Butzel Long PC Canada Customs & Rev Agency Canada Customs & Rev Agency Charter Township Of Plymouth City Of Albemarle City Of Barberton City Of Battle Creek City Of Canton City Of Dover City Of Dover City Of Evart Recreation Dept City Of Fullerton City Of Havre De Grace City Of Longview City Of Los Angeles City Of Phoenix City Of Roxboro City Of St Joseph City Of Sterling Heights City Of Williamston City Treasurer Colbond Inc Collector Of Revenue Collins & Aikman Corp Dayton Bag & Burlap Co Dow Chemical Co DuPont Dykema Gossett PLLC Enerflex Solutions LLC ER Wagner Manufacturing Exxon Chemicals Fisher Automotive Systems Fisher America Inc Freudenberg Nok Inc 1007 N Market St Auburn Hills Plymouth Atlanta Charlotte Atlanta Pittsburgh MI MI GA NC GA PA 48326-2613 48170 30348-5499 28289-0691 30374 15264-0387 Director's Office for Taxpayer Services Division PO Box 105499 PO Box 890691 PO Box 740434 PO Box 640387

ADDRESS1 1062 S 4th Ave 590 Madison Ave 505 S Neil St PO Box 16253 PO Box 849 1609 Biddle Ave 100 Bayer Rd Bldg 16 2 North LaSalle St Ste 1020 2 North LaSalle St Ste 1020 401 S Steele Ste 100 Bloomfield Hills Pkwy Ste 100 1 5 Notre Ave 2204 Walkley Rd PO Box 8040 144 N Second St 104 3rd St NW 10 N Division St Suite 114 49014 PO Box 9951 484 Middle Rd PO Box 818 200 South Main St 303 W Commonwealth Ave 711 Pennington Ave PO Box 1952 201 N Figueroa St No 786 200 W Washington St 13th Fl PO Box 128 700 BRd St 40555 Utica Rd 161 E Grand River 100 Mcmorran Sand Hill Rd 201 N Second St 250 Stephenson Hwy 322 Davis Ave 23030 Dow Center DuPont Legal D 7156 400 Renaissance Center 1515 Equity Dr 200 4611 North 32nd St 13501 Katy Fwy

CITY Sidney New York Champaign Greenville Athens Wyandotte Pittsburgh Chicago Chicago Ionia Bloomfield Hills Sudbury Ottawa Plymouth Albemarle Barberton Battle Creek Canton Dover Dover Evart Fullerton Havre De Grace Longview Los Angeles Phoenix Roxboro St Joseph Sterling Heights Williamston Port Huron Enka St Charles Troy Dayton Midland Wilmington Detroit Troy Milwaukee Houston

STATE OH NY IL SC TN MI PA IL IL MI MI ON ON MI NC OH MI OH NH NH MI CA MD TX CA AZ NC MI MI MI MI NC MO MI OH MI DE MI MI WI TX

ZIP 45365-8977 10022 61820-2500 29606 37371-0849 48192 15205-9707 60602 60602 48846 48304 P3A 5C2 K1A 1B1 48170-4394 28002-0190 44203 49014 44711-9951 3820 03820-0818 49631 92632 21078 75606 90012 85003 27573 49085-1355 48311-8009 48895 48060 28782 63301 48083 45403-2910 48674-0001 19898 48243 48084-8084 53209-6023 77079-1305

Ga Dept Of Revenue Gaston County Ge Capital Ge Capital

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 1 of 4

Served via Overnight Mail

CREDITOR NAME Ge Capital Ge Capital Comm Serv Astro Dye Harford County Revenue co Highwoods Properties Llc co Highwoods Properties Llc co Rudolph libbe Properties Attn Lease Administration TN 37203-5223

CREDITOR NOTICE NAME

ADDRESS1 PO Box 642444 PO Box 60500 220 South Main St

ADDRESS2

CITY Pittsburgh Charlotte Bel Air

STATE PA NC MD

ZIP 15264 28260 21014

COUNTRY

Highwoods Forsyth Lp

of the City of Montgomery

Canada

SBSE Insolvency Unit Bill Weeks Tim Gorman Laura Kelly Lilia Roman C Garland Waller

Canada Canada

Highwoods Forsyth Lp Hnk Michigan Properties Indiana Department Of Revenue Indiana Dept Of Revenue Industrial Development Board Industrial Leasing Company Industrial Truck Sales & Svc Inmet Division of Multimatic Internal Revenue Service Intertex World Resources Trintex Corp Invista ISP Elastomer Janesville Products Keith Milligan Lake Erie Products Lear Corp Manpower Meridian Magnesium Meridian Park Ministre Du Revenu Du Quebec Municipality Of Port Hope North Loop Partners Ltd Office of Finance of Los Angeles Orlando Corporation co Beer Wells Real Estate Bankruptcy Auditor Sara Eagle & Gail Perry Barb Krzywiecki Woody Ban

Attn Lease Administration 7255 Crossleigh Court Ste 108 100 N Senate Ave PO Box 7218 PO Box 4660 PO Box 1803 PO Box 1807 35 West Milmot St Box 330500 Stop 15 500 Wedowee St 601 S LA Salle St Ste 310 PO Box 4346 2700 Patterson Ave 3745 C Us Hwy 80 W 321 Foster Ave 21557 Telegraph Rd 30800 Northwestern Hwy 2001 Industrial Dr 2707 Meridian Dr 3800 Marly PO Box 117 PO Box 3449 3700 Wilshire Ste 310 6205 Airport Rd

NC OH IN IN AL MI NC ON MI GA IL TX MI AL IL MI MI MI NC QC ON TX CA ON

27604 43617 46204-2253 46207-7218 36103-4660 49501 27702-1807 L4B 1L7 48232 30108-1541 60605-1725 77210 49546 36870 60191 48034 48334 48827 27834 G1X 4A5 L1A 3V9 75606 90010 L4V 1E3

Canada

Canada Canada

Pension Benefit Guaranty Corporation Pine River Plastics Inc PolyOne Corp Prestige Property Tax Special Princeton Properties Progressive Moulded Products Qrs 14 Paying Agent Qrs 14 Paying Agent Inc Railroad Drive Lp Dan Thiffault

1200 K St NW 1111 Fred W Moore Hwy 33587 Walker Rd 1025 King St East 678 Princeton Blvd 9024 Keele St Church St Station 50 Rockefeller Lobby 2 100 Vesper Executive Pk

2120 West End Ave Ste 100 Nashville 3100 Smoketree Ct Ste 600 Raleigh Toledo Indianapolis Indianapolis Montgomery Grand Rapids Durham Richmond Hill Detroit Bowdon Chicago Houston Grand Rapids Phenix Wood Dale Southfield Farmington Hills Eaton Rapids Greenville Ste Foy Port Hope Longview Los Angeles Mississauga Office of the Chief Counsel Washington St Clair Avon Lake Cambridge Lowell Concord PO Box 6529 New York New York Tyngsboro DC MI OH ON MA ON NY NY MA 20005-4026 48079-4967 44012 N3H 3P5 1851 L4K 2N2 10249 10020-1605 01879-2710

Receiver General For Canada Receiver General For Canada Receiver General for Canada Receiver General For Canada Revenue Canada Revenue Canada Riverfront Plastic Products Inc Securities and Exchange Commission

Canada Customs & Rev Agency Technology Ctr 875 Heron Rd Industry Canada Als Financial Postal Station D Box 2330 700 Leigh Capreol 11 Station St Ottawa Technology Centre 275 Pope Rd Ste 102 George Tabry 780 Hillsdale St Midwest Regional Office 175 W Jackson Blvd Ste 900

875 Heron Rd

Ottawa Ottawa Dorval Belleville Ottawa Summerside Wyandotte Chicago

ON ON QC ON ON PE MI IL

K1A 1B1 K1P 6K1 H4Y 1G7 K8N 2S3 K1A 9Z9 C1N 5Z7 48192-7120 60604

Canada Canada Canada Canada Canada Canada

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 2 of 4

Served via Overnight Mail

CREDITOR NOTICE NAME Christine Brown Peter Pantaleo Erin Casey & Alice Eaton Sales & Use Tax Division Lorraine Zinar Daniel Watson 50 N Ripley St Dept Of Commerce & Nat Res Linda King Matthew Rick Asst Attorney General State Of Michigan Mc State Secondary Complex

CREDITOR NAME Select Industries Corp Simpson Thacher & Bartlett LLP South Carolina Dept Of Revenue Southco Standard Federal Bank State Of Alabama State Of Michigan State Of Michigan State Of Michigan State Of Michigan State Of Michigan State of Michigan Jennifer Nelles US Trustee First Plaza County Of Fresno Bruce B Galletly Raymond Soucie Of Ingersoll PO Box 67 PO Box 2228 PO Box 30744

ADDRESS1 240 Detrick St 425 Lexington Ave PO Box 125 210 N Brinton Lake Rd 2600 West Big Beaver Rd Department Of Revenue PO Box 30004 PO Box 30457 PO Box 30754 Dept 77833 7150 Harris Dr PO Box 30015 430 W Allegan St

ADDRESS2

CITY Dayton New York Columbia Concordville Troy Montgomery Lansing Lansing Lansing Detroit Lansing Lansing

STATE OH NY SC PA MI AL MI MI MI MI MI MI

ZIP 45404-1699 10017-3954 292020101 19331-9331 48084 36104 48909 48909-7957 48909 48277-0833 48909 48918-0001

COUNTRY

Canada

Canada

Farmville Downtown Partnership

PO Box 100 PO Box 100

Canada

Fsia Inc

Randy Lueth Tom Tekieke

Office of Child Support 211 W Fort St Ste 700 24901 Northwestern Hwy 302 1985 Blvd Se PO Box 1192 21 Albert St PO Box 538308 1400 Stephenson Hwy 130 Oxford St 2nd Fl 126 North Pearl St 1306 E Triumph Dr 356 Main St 115 West Church St 30 King St East 100 Old River Rd PO Box 520 PO Box 67 315 North Main St 200 E Big Beaver PO Box 33525 7201 W Friendly Ave 942 Brooks Ave 800 Standard Pkwy

Lansing Detroit Southfield Hickory Fresno Trenton Atlanta Troy Ingersoll Pageland Urbana Farmington Farmville Gananoque Lincoln Old Fort Pageland Troy Troy Detroit Greensboro Holland Auburn Hills

MI MI MI NC CA ON GA MI ON SC IL NH NC ON RI NC SC NC MI MI NC MI MI

48909-8244 48226 48075 28602 937151192 K8V 5R1 30353 48083 N5C 2V5 29728 61802 3835 27828-1621 K7G 2T6 2865 28762 29728 27371 48083 48232 27410-6237 49423 48326-1415

Attn Civil Division Jerry Dittrich General Fax Terry Nardone Adriana Avila Blue Point Capital Bpv Lowell LLC

State of Michigan Central Functions Unit Stephen E Spence Summit Property Management Inc Tate Boulevard I Llc Tax Collector Tcs Realty Ltd Teknor Financial Corporation TG North America The Corporation Of The Town The Town Of Pageland Tom Heck Truck Service Town Of Farmington Town Of Farmville Town Of Gananoque Town Of Lincoln Finance Office Town Of Old Fort Town Of Pageland Town Of Troy Tr Associates Treasurer City Of Detroit Unifi Inc Uniform Color Co Unique Fabricating Inc United States Attorney for the Eastern District of Michigan Valeo Inc Valiant Tool & Mold Inc Vari Form Inc Vericorr Packaging fka CorrFlex Packaging Vespera Lowell Llc Village Of Holmesville Village Of Rantoul 211 W Fort St Ste 2001 3000 University Dr 6775 Hawthorne Dr 12341 E 9 Mile Rd 251 Industrial Dr 10 Livingston Pl 2nd Fl 205 Millersburg Rd 333 S Tanner One Village Center Dr Detroit Auburn Hills Windsor Warren Evart Greenwichn PO Box 113 Holmesville Rantoul Van Buren Ste PO RFQ Office Township

MI MI ON MI MI CT OH IL MI

48226 48326-2356 N8T 3B8 48089 49631-8517 6830 44633 61866 48111

Canada

Visteon Climate Control

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 3 of 4

Served via Overnight Mail

CREDITOR NAME co Lincoln Harris Llc Hal Novikoff 10101 Claude Freeman Dr Ste 200 N 51 W 52nd St 31100 Telegraph Rd Ste 200 Charlotte New York Bingham Farms NC NY MI 28262-2337 10019 48025

CREDITOR NOTICE NAME

ADDRESS1

ADDRESS2

CITY

STATE

ZIP

COUNTRY

W9 Lws Real Estate Limited Wachtell Lipton Rosen & Katz Wellington Green LLC

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

Page 4 of 4

EXHIBIT B Summary of Legal Fees and Expenses For the Period May 1, 2006 through August 31, 2006
Matter Number 3 Matter Description Total Billed Hours 761.60 548.70 775.10 1,170.00 167.90 213.70 892.20 521.60 279.00 297.10 1,254.10 31.10 49.90 62.50 239.50 11.10 31.80 348.10 1,292.30 121.20 155.20 104.50 73.90 174.00 1.50 47.90 96.80 5.10 14.80 9,742.20 Total Fees Requested $383,452.00 $229,352.50 $393,536.50 $223,245.00 $73,847.50 $92,281.50 $402,766.00 $189,872.00 $85,343.00 $88,658.50 $655,329.50 $11,946.50 $23,922.00 $33,601.50 $128,339.00 $5,328.00 $18,767.00 $175,033.50 $611,072.50 $52,136.50 $85,368.00 $67,493.50 $30,999.50 $74,422.50 $757.50 $20,458.00 $47,158.00 $2,161.50 $5,286.00 $4,211,935.00 Total Expenses Requested $16,676.24 $879.46 $4,589.65 $25,172.22 $1,818.29 $1,739.13 $3,970.47 $16,016.55 $3,341.55 $668.18 $5,886.28 $203.72 $215.65 $255.94 $82,096.97 $0.00 $39.27 $2,512.77 $10,950.68 $1,480.69 $1,198.90 $9.20 $462.58 $438.42 $0.00 $225.96 $29.85 $1.85 $10.90 $180,891.37 Total Compensation $400,128.24 $230,231.96 $398,126.15 $248,417.22 $75,665.79 $94,020.63 $406,736.47 $205,888.55 $88,684.55 $89,326.68 $661,215.78 $12,150.22 $24,137.65 $33,857.44 $210,435.97 $5,328.00 $18,806.27 $177,546.27 $622,023.18 $53,617.19 $86,566.90 $67,502.70 $31,462.08 $74,860.92 $757.50 $20,683.96 $47,187.85 $2,163.35 $5,296.90 $4,392,826.37

Adversary Proceedings and Contested Matter 5 Asset Analysis 6 Business Operations 7 Case Administration 8 Cash Collateral/DIP Financing 9 Claims Administration and Objections 11 Executory Contracts and Unexpired Leases 12 Hearings Fee/Retention Application /Objections 13 (Kirkland & Ellis Only) Fee/Retention Application/Objections 16 (Other Professionals) Disclosure Statement and Plan of 17 Reorganization 18 Reclamation 19 Relief from Automatic Stay 21 Tax Issues 22 Travel 23 Utilities 24 Environmental 25 International 26 Labor and Employee Benefits 27 Avoidance Actions 28 Corporate and Securities Matters 29 Stakeholders Communications 34 Insurance 35 Intellectual Property 37 Shareholder Litigation 39 Liens 40 Vendor/Supplier Matters 41 Document Subpoena Investigation 42 Termination of Joint Venture Totals for Matters

Total Fees Requested: Blended Rate of Professionals (Including Paraprofessionals): Blended Rate of Professionals (Excluding Paraprofessionals):

$4,211,935.00 $432.34 $526.16

K&E 11405404.8

Summary of Hours Billed by Attorneys and Paraprofessionals For the Period May 1, 2006 through August 31, 2006
Name of Professional Person David A. Agay Ameer I. Ahmad Tanvir Alam Holden Bixler Nicole G. Brightbill Grant H. Caldis Marc J. Carmel Erik W. Chalut Richard M. Cieri Lisa Cox Brian E. Davis Thad Davis Deborah V. Dunn David L. Eaton Lisa G. Esayian Amanda N. Feltman Laura L. Fraedrich Rebecca O. Fruchtman Mark E. Grummer John F. Hartmann, P.C. Atief Heermance Gregory T. Heyman Amy A. Hijjawi Vicki V. Hood Anne Huber Elisa Hughes Gates S. Hurand Melissa B. Hursey John S. Irving, Jr. Gordon W. Johnson Colin R. Kass Natalie H. Keller Marc Kieselstein, P.C. Gregg Kirchhoefer, P.C. Lisa G. Laukitis Lori A. Lenard Position with the Applicant and Year Admitted Associate 1998 Associate 2001 Associate 2003 Of Counsel 2002 Associate Associate Associate Associate Partner Associate Partner Associate Partner Partner Partner Associate Of Counsel Of Counsel Partner Partner Associate Associate Of Counsel Partner Partner Associate Associate Attorney Of Counsel Partner Partner Partner Partner Partner Partner Of Counsel 2005 Pending 2000 1999 1981 2000 1998 2005 1995 1978 1991 2005 1995 1987 1976 1987 2005 2003 1989 1979 1992 2004 Pending 2001 1965 1988 1996 1997 1988 1982 2000 1992 Department Restructuring Corporate Restructuring Restructuring Labor Corporate Restructuring Restructuring Restructuring Real Estate Real Estate Taxation Trusts and Estates Restructuring Litigation Litigation International Trade Restructuring Environment Litigation Employee Benefits Litigation Restructuring Employee Benefits Restructuring Intellectual Property Litigation Restructuring Labor Restructuring Litigation Taxation Restructuring Intellectual Property Restructuring Employee Benefits Hourly Billing Rate $545.00 $430.00 $480.00 $280.00 $275.00 $315.00 $295.00 $350.00 $510.00 $545.00 $510.00 $545.00 $825.00 $355.00 $395.00 $475.00 $275.00 $325.00 $525.00 $775.00 $545.00 $275.00 $445.00 $595.00 $645.00 $645.00 $260.00 $315.00 $475.00 $490.00 $695.00 $675.00 $675.00 $315.00 $295.00 $295.00 $695.00 $745.00 $515.00 $545.00 $745.00 $695.00 $545.00 $495.00 Total Billed Hours 30.50 18.70 45.10 70.60 13.30 44.40 126.90 116.20 418.30 532.90 5.90 2.40 64.60 1.40 5.40 3.50 1.10 8.70 0.60 512.50 2.50 0.50 2.50 5.00 19.80 0.20 13.50 6.00 91.00 21.10 378.00 256.50 8.30 121.60 163.30 13.70 29.70 0.70 3.80 0.80 6.70 74.40 0.40 5.00 Total Compensation $16,622.50 $8,041.00 $21,648.00 $19,768.00 $17,643.50 $78,105.50 $503,763.50 $4,317.00 $53,295.00 $2,630.00 $1,662.50 $3,130.00 $315.00 $397,187.50 $1,362.50 $137.50 $1,112.50 $2,975.00 $12,771.00 $129.00 $5,400.00 $53,564.00 $262,710.00 $173,137.50 $5,602.50 $38,304.00 $48,173.50 $4,041.50 $20,641.50 $521.50 $1,957.00 $436.00 $4,991.50 $51,708.00 $218.00 $2,475.00

2
K&E 11405404.8

Name of Professional Person Micah E. Marcus Daryll Marshall Elisabeth Martin Todd F. Maynes, P.C. Andrew P.R. McDermott Alexandra Mihalas Joy L. Monahan Ryan Morettini Michelle Mulkern Dennis M. Myers, P.C. Linda K. Myers, P.C. Maureen D. O'Brien Rebecca Oldroyd Adam C. Paul Joshua Z. Rabinovitz Victoria Reznik Yosef J. Riemer Ray C. Schrock Joseph Serino, Jr. Jesse Sheley Karen G. Sodke Matthew O. Solum R. Timothy Stephenson Ian Taplin Douglas D. Timmer Paul Wierbicki Scott R. Zemnick Paul Zier Totals for Attorneys

Position with the Applicant and Year Admitted Associate Partner Associate Partner Associate Partner Associate Associate Associate Partner Partner Partner Associate Partner Associate Partner Partner Partner Partner Associate Partner Partner Partner Partner Partner Associate Associate Partner 1999 1988 2002 1988 2003 1991 1997 2004 2002 1996 1990 1998 2005 1997 2000 2000 1985 1998 1989 2003 1998 2000 1990 1977 1995 2005 2001 2000

Department Restructuring Corporate Corporate Taxation Restructuring Employee Benefits Restructuring Litigation Corporate Corporate Corporate Employee Benefits Employee Benefits Restructuring Litigation Litigation Litigation Restructuring Litigation Corporate Corporate Litigation Labor Taxation Corporate Restructuring Restructuring Corporate

Hourly Billing Rate $445.00 $480.00 $475.00 $430.00 $450.00 $795.00 $395.00 $645.00 $350.00 $395.00 $445.00 $395.00 $745.00 $745.00 $475.00 $315.00 $595.00 $435.00 $455.00 $505.00 $675.00 $595.00 $645.00 $355.00 $395.00 $495.00 $505.00 $595.00 $990.00 $525.00 $295.00 $350.00 $480.00 $510.00 $475.00

Total Billed Hours 93.40 58.40 20.80 11.90 3.60 24.90 204.50 0.30 50.90 129.70 49.30 0.10 13.20 9.60 91.00 11.70 54.50 0.60 1.30 431.00 16.30 963.80 155.60 99.90 78.30 4.20 185.90 43.70 0.50 8.80 187.00 193.00 348.70 414.30 1.50 7,210.20

Total Compensation $69,595.00 $9,880.00 $6,737.00 $19,795.50 $80,777.50 $193.50 $17,815.00 $73,170.00 $39.50 $9,834.00 $7,152.00 $43,225.00 $3,685.50 $32,427.50 $852.50 $217,655.00 $11,002.50 $573,461.00 $100,362.00 $66,393.00 $2,079.00 $93,879.50 $26,001.50 $495.00 $4,620.00 $122,715.00 $378,669.00 $712.50 $3,793,722.50

Name of Paraprofessional Person Jesse Aguilar April Albrecht Dionna Alexander Nandita Anand David Andrews

Position with the Applicant Legal Assistant Technology Services Project Assistant Case Assistant Project Assistant

Department Restructuring Litigation Restructuring Intellectual Property Restructuring

Hourly Billing Rate $215.00 $160.00 $140.00 $150.00 $150.00 $150.00 $160.00

Total Billed Hours 45.80 4.50 165.90 117.10 15.00 21.50 23.70

Total Compensation $9,847.00 $720.00 $40,791.00 $2,250.00 $7,017.00

3
K&E 11405404.8

Name of Paraprofessional Person Henry Bankes-Jones James Barlow Jason Berrebi Neil P. Bohan Derek J. Bremer John C. Crees William G. Cross Michelle T. Denny Kevin Donnelly Robert Esris Jacob Goldfinger Adam J. Gorman Adir Greenfeld Scott Huff Claude W. Irmis Ellen J. Kratofil Whitney Lappley Maureen McCarthy Jane B. Mackie Mary Mortell Elizabeth Ori Brandon L. Phillips Mary M. Plastina Rocio Renteria Linda A. Scussel James R. Strohl Gary M. Vogt Scott F. Walker Nancy L. Warner Ian Whalen PeiSan Yee Joseph Zlatnik Library Research

Position with the Applicant Legal Assistant Legal Assistant Law Clerk Project Assistant Technology Services Project Assistant Project Assistant Legal Assistant Project Assistant Technology Services Legal Assistant Legal Assistant Case Assistant Project Assistant Legal Assistant Restructuring Specialist Project Assistant Legal Assistant Project Assistant Project Assistant Project Assistant Legal Assistant Legal Assistant Project Assistant Conflicts Analyst II Legal Assistant Legal Assistant Legal Assistant Legal Assistant Case Assistant Technology Services Case Assistant Research Specialist

Department Corporate Litigation Litigation Restructuring Litigation Restructuring Restructuring Litigation Restructuring Litigation Restructuring Restructuring Litigation Restructuring Restructuring Administrative Services Restructuring Restructuring Restructuring Restructuring Restructuring Litigation Employee Benefits Restructuring Administrative Services Restructuring Restructuring Restructuring Corporate Litigation Litigation Litigation Administrative Services

Hourly Billing Rate $260.00 $205.00 $185.00 $150.00 $195.00 $150.00 $160.00 $150.00 $205.00 $215.00 $140.00 $195.00 $185.00 $205.00 $185.00 $140.00 $150.00 $240.00 $210.00 $140.00 $185.00 $150.00 $160.00 $140.00 $140.00 $150.00 $155.00 $165.00 $205.00 $140.00 $185.00 $215.00 $240.00 $185.00 $230.00 $140.00 $195.00 $140.00 $185.00

Total Billed Hours 3.00 3.50 19.00 195.00 0.80 240.00 112.10 3.00 15.50 43.20 67.30 0.30 7.20 1.20 532.80 0.50 0.90 1.30 9.90 6.50 118.10 275.50 291.40 1.50 34.20 28.60 0.50 1.00 28.90 9.40 1.90 12.70 7.30 32.50 7.50 2.30 3.00 9.20 10.00 2,532.00

Total Compensation $780.00 $717.50 $3,515.00 $29,250.00 $156.00 $53,936.00 $450.00 $12,465.50 $9,422.00 $58.50 $1,578.00 $98,568.00 $70.00 $135.00 $312.00 $2,079.00 $910.00 $21,848.50 $87,949.00 $210.00 $9,078.00 $242.50 $5,924.50 $1,316.00 $351.50 $2,730.50 $1,752.00 $6,012.50 $1,725.00 $322.00 $585.00 $1,288.00 $1,850.00 $418,212.50

Totals for Paraprofessionals

4
K&E 11405404.8

Summary of Disbursements For the Period May 1, 2006 through August 31, 2006 Disbursements Telephone Fax Charges Copying and Binding Filing, Calendar and Court Reporter Fees Local Transportation Meals Postage and Messenger Service Research and Document Procurement Expert Fees Travel and Airfare Trial, Office and Rental Expenses Total Amount $6,647.56 $113.50 $52,443.72 $3,254.25 $1,854.09 $3,812.00 $4,271.22 $24,090.42 $1,664.52 $82,277.59 $462.50 $180,891.37

5
K&E 11405404.8

Anda mungkin juga menyukai