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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION IN THE MATTER OF: Collins & Aikman

Corporation, et. al.,

Debtors. /

Bankruptcy Case No. 05-55927 (Jointly Administered) Honorable Steven W. Rhodes Chapter 11

OBJECTION BY H.P. PELZER AUTOMOTIVE SYSTEMS, INC. TO CONFIRMATION OF THE FIRST AMENDED JOINT PLAN OF COLLINS & AIKMAN CORPORATION AND ITS DEBTOR SUBSIDIARIES NOW COMES H.P. Pelzer Automotive Systems, Inc. ("H.P. Pelzer") by and through its attorneys, Stevenson & Bullock, P.L.C., and for its Objection to the Confirmation of the First Amended Joint Plan of Collins & Aikman Corporation and its Debtor Subsidiaries states as follows: 1. On May 17, 2005 (the "Petition Date"), Collins & Aikman Corporation

and its debtor subsidiaries (collectively for purposes of this Objection the "Debtors") filed petitions for relief pursuant to Chapter 11 of Title 11 of the United States Code (the "Bankruptcy Code"). 2. The Disclosure Statement submitted to the Court in support of the Plan

was approved on February 9, 2007. The current deadline for objecting to confirmation of the Plan and for submission of all balloting materials relating to the Plan is May 7, 2007. 3. 4. 5. H.P Pelzer is a supplier to Debtors. H.P. Pelzer is also a customer of Debtors. H.P. Pelzer maintains, without limitation, a right of setoff and/or Additionally, H.P. Pelzer is listed on the Nonexclusive

recoupment against Debtors.

List of the Retained Causes of Action which is attached to the Plan as Exhibit A. 6. The claims of H.P. Pelzer are secured; therefore, H.P. Pelzer believes that

it has been classified and shall be treated as an "Other Secured Claim" as that term is defined in Article I.A.94 of the Plan.

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H.P. Pelzer's "Other Secured Claim" is an "Allowed Other Secured

Claim." Article. I.A.4 and 5 of the Plan. 8. Allowed Other Secured Claims are in Class 1 and are unimpaired.

Article. III.B.1. 9. Without limiting the generality of the foregoing, if there is an objection

to H.P. Pelzer's "Other Secured Claim" or any other claims or causes of action are initiated by contested matter or adversary proceeding (or any other way) against H.P. Pelzer by Debtors or any of the various trusts established by the Plan, then the injunctive provisions of the Plan, which are imposed as of the Effective Date of the Plan, appear to prohibit H.P. Pelzer from defending or asserting its right of setoff, recoupment or raising any other defenses. Article XII.E. of the Plan. 10. The Plan violates and does not satisfy the requirements of, inter alia, the United States Bankruptcy Code. 11. In order for the Plan as proposed to be confirmed, the plan proponents must satisfy the requirements contained in 11 U.S.C. 1129. 12. The Plan does not satisfy the statutory requirement of 11 U.S.C.

1129(a)(1), (2), (3), (7) and (8). 13. The Plan is drafted so that the rights of parties like H.P. Pelzer are

effectively eliminated on the Effective Date by the injunctive provision in Article XII (E) of the Plan, without compensation or any reservation of rights or defenses (or the "indubitable equivalent" that would be required under 11U.S.C. 1129(b)(2)(A)(iii)). 14. The Plan does not comply with applicable provisions of the United States Bankruptcy Code; therefore, the Plan cannot be confirmed and this Court should deny confirmation. 15. H.P. Pelzer suggests including the following language in any order of

confirmation that may be entered: Neither the provisions of Plan Article XII. E nor any other provision of the Plan shall enjoin or otherwise preclude the assertion at any time of a right of setoff, recoupment or any defense (affirmative or otherwise) by any party to an objection to claim, other contested matter or adversary proceeding. Such rights and/or defenses are preserved and are not reduced or impacted by the Plan.

16. In light of the unavailability of Exhibit E and F of the Plan as of the date of this Objection, H.P. Pelzer reserves the right to supplement this Objection to address any issues raised once those Exhibits are available. 17. H.P. Pelzer reserves the right to modify or supplement this Objection. WHEREFORE, H.P. Pelzer respectfully requests for all the foregoing reasons, the Court should deny confirmation of the First Amended Joint Plan.

Respectfully submitted, /s/ Charles D. Bullock (P55550) Stevenson & Bullock, P.L.C. Attorneys for H.P. Pelzer Automotive Systems, Inc. 29200 Southfield Rd., Suite 210 Southfield, MI 48076 (248)423-8200 ext. 224 cbullock@gatecom.com Dated: May 5, 2007

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION IN THE MATTER OF: Collins & Aikman Corporation, et. al., Bankruptcy Case No. 05-55927 (Jointly Administered) Honorable Steven W. Rhodes Chapter 11 / PROOF OF SERVICE Charles D. Bullock certifies that on the 5th day of May, 2007 a copy of Objection By H.P. Pelzer Automotive Systems, Inc. to Confirmation of the First Amended Joint Plan of Collins & Aikman Corporation and its Debtor Subsidiaries was served upon the Core Service List, the Rule 2002 Service List, including the following parties in accordance with the First Amended Notice, Case Management and Administrative Procedures, either electronically, via facsimile, or by causing a copy to be deposited via First Class U.S. Mail. I declare that the statement above is true to the best of my information, knowledge and belief. Marian J. Mack Office of the United States Trustee 211 W. Fort Street, Suite 700 Detroit, MI 48226 Kirkland & Ellis, LLP Attn: Richard M. Cieri, Esq. Citigroup Center 153 East 53rd Street New York, NY 10022 (Facsimile: (212) 446-4900) Kirkland & Ellis, LLP Attn: David L Eaton, Esq. Ray C. Schrock, Esq. Marc J. Carmel, Esq. 200 East Randolph Drive Chicago, IL 60601 (Facsimile: (312) 861-2200) Michael S. Stamer Akin, Gump, Strauss, Hauer & Feld, L.L.P. 590 Madison Avenue New York, NY 10022 Carson Fischer, PLC Attn: Joseph M. Fischer, Esq. 4111 Andover Rd. Fl. 2W Bloomfield Hills, MI 48302-1924 (Facsimile: (248) 644-1832) Paul J. Randel, Esq. Office of the United States Trustee 211 W. Fort Street, Suite 700 Detroit, MI 48226

Debtors.

Thomas B. Radom Butzel Long, P.C. 100 Bloomfield Hills Parkway Bloomfield Hills, MI 48304

Peter V. Panteleo Alice B. Eaton Simpson Thacher & Bartlett, LLP 425 Lexington Avenue New York, NY 10017

Harold S. Novikoff Gregory E. Pessin Wachtell, Lipton, Rosen & Katz 51 West 52nd Street New York, NY 10019

/s/ Charles D. Bullock (P55550) Stevenson & Bullock, P.L.C. 29200 Southfield Rd., Suite 210 Southfield, MI 48076 (248)423-8200 ext. 224 cbullock@gatecom.com

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