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

, ) a Delaware corporation, ) ) Debtor. ) )

Chapter 11 Case No. 05-55927-SWR Hon. Steven W. Rhodes

LIMITED OBJECTION OF PHILLIPS TOOL AND MOULD (LONDON) LTD. TO DAIMLERCHRYSLER CORPORATIONS MOTION FOR CONTINGENT RELIEF FROM AUTOMATIC STAY TO OBTAIN POSSESSION OF TOOLING Phillips Tool and Mould (London) Ltd. (Phillips), for its Limited Objection to DaimlerChrysler Corporations Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling (the Motion) states: 1. Motion. 2. Contained in the Motion are representations by DCC that: i.) ii.) iii.) iv.) DCC owns the Tooling; Motion at 15, 24. the Debtor has no equity in the Tooling; Motion at 41. DCC has paid the Debtor for the Tooling. Motion at 22-23. Debtors obligation to turn the Tooling over to DCC is absolute and On September 12, 2005, DaimlerChrysler Corporation (DCC) filed the

unconditional under the Terms and Conditions. Motion at 40. 3. Phillips claims a lien on certain molds (Phillips Molds) pursuant to a

statute commonly known as the Michigan Mold Lien Act, MCL 445.611 et seq., (the

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Act), that it fabricated for the Debtor that are used to manufacture parts for DCC vehicles and believes that some or all of the Phillips Molds may be included in the tooling referenced in the Motion of which DCC proposes to take possession from the Debtor. 4. Pursuant to the Act, prior to shipping the Phillips Molds to the Debtor,

Phillips properly affixed its name and address on the Molds. 5. Phillips filed UCC-1 financing statements relative to the Phillips Molds as

required by the Act. 6. Phillips has an ownership interest in the Phillips Molds; alternatively, it has

a statutory lien against the Phillips Molds. 7. The Motion fails to recognize Phillips ownership interest/statutory lien on

the Phillips Molds and to provide for payment to satisfy Phillips lien on the Phillips Molds. 8. According to DCCs supporting documentation attached to the Motion,

Phillips believes that DCC may have paid the Debtor for the Phillips Molds, yet Phillips has not been paid by the Debtor for the Phillips Molds. 9. Phillips objects to DCCs requested relief to the extent that Phillips

ownership interest/statutory lien on the Phillips Molds is not recognized and/or satisfied. 10. Phillips does not object to the proposed relief requested by DCC relative

to molds and tools other than the Phillips Molds. THEREFORE, Phillips respectfully requests that the Court deny DaimlerChrysler Corporations Motion for Contingent Relief from Automatic Stay to Obtain Possession of

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Tooling to the extent that it fails to recognize and satisfy Phillips statutory lien on the Phillips Molds and grant such further and additional relief as deemed just and proper. Respectfully submitted,

________/s/ Dennis W. Loughlin____ LYNN M. BRIMER (P43291) DENNIS W. LOUGHLIN (P57084) Attorneys for Phillips Tool and Mould (London) Ltd. RAYMOND & PROKOP, P.C. 26300 Northwestern Hwy, 4th Floor P.O. Box 5058 Southfield, MI 48086-5058 (248) 357-3010; fax (248) 357-2720 Dated: September 29, 2005
ECF Certificate of Service I hereby certify that on September 29, 2005, I electronically filed Limited Objection of Phillips Tool and Mould (London) Ltd. to General Motors Corporations Motion for Contingent Relief from Automatic Stay to Obtain Possession of Tooling with the Clerk of the Court using the ECF system which will send notification of such filing to: attorneys of record, and I hereby certify that I have mailed by US Postal Service the paper to the non-ECF participants. By: /s/ Dennis W. Loughlin Dennis W. Loughlin (P57084) 26300 Northwestern Hwy., 4th Floor P.O. Box 5058 Southfield, MI 48076-5058 (248) 357-3010 dloughlin@raypro.com

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