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

et al. Debtors. ) ) ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

LANDLORDS OBJECTION TO: DEBTORS MOTION FOR ORDER APPROVING ASSUMPTION AND ASSIGNMENT OF THE OWOSSO LEASE One If By Land, LLC (Landlord) hereby objects to Debtors Motion For Order Approving Assumption And Assignment Of The Owosso Lease (Motion) with respect to that certain lease agreement dated June 15, 2004 (the Owosso Lease), by and between Landlord and Owosso Thermo Forming, LLC (Owosso), and the proposed assignment of the Owosso Lease to S-Group Automotive Ltd. (S-Group). In support of its objection, Landlord states as follows: 1. Whether or not there has been a default under a Lease, a Debtor in possession may only

assign an unexpired lease if it first assumes the lease in accordance with Section 365(a) of the Bankruptcy Code and provides adequate assurance of future performance by the assignee. See 11 U.S.C. 365(f)(2). Among other things, adequate assurance may be provided by demonstrating the assignees financial health and its ability and intent to perform under the assigned agreement. See, e.g., In re Bygraph, Inc., 56 B.R. 596, 605-06 (Bankr. S.D.N.Y. 1986) (stating the adequate assurance of future performance is present when the prospective assignee of the lease has financial resources and has expressed the willingness to devote sufficient funding to the business in order to give it a strong likelihood of succeeding). 1

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In the Motion, Debtors fail to provide any demonstration of adequate assurance of future

performance. Debtors Motion fails to provide any evidence of the proposed assignees financial health or its likelihood of success. WHEREFORE, Landlord respectfully requests this Court: deny Debtors Motion; require Debtors to demonstrate the financial health and ability of the proposed assignee; or provide such other and future adequate assurance of future performance, including corporate and personal guarantees, as is just and proper.

Dated: February 9, 2007

Respectfully submitted, LAW OFFICE OF TROY R. TAYLOR PLLC

___/S/ Troy R. Taylor____________________ Troy R. Taylor (P40776) Attorney for One If By Land LLC Law Office of Troy R. Taylor PLLC 126 N Center St Ste C Northville, MI 48167 (248) 348-6988 Fax: (248) 348-6922

SILVERMAN & MORRIS, P.L.L.C.

By:

/s/ Thomas R. Morris THOMAS R. MORRIS (P39141) Co-counsel for One If By Land LLC 7115 Orchard Lake Road, Suite 500 West Bloomfield, Michigan 48322 morris@silvermanmorris.com telephone (248) 539-1330; fax (248) 539-1355

Dated: February 9, 2007

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