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

Corp., et al, Debtors. ______________________________/ QCR TECH, LLC S AMENDED OBJECTION TO CURE AMOUNTS CONTAINED IN THE ORDER APPROVING BIDDING PROCEDURES, ETC. IN CONNECTION WITH THE DEBTORS MOTION FOR THE ENTRY OF ORDERS APPROVING BIDDING PROCEDURES, SALE OF CERTAIN ASSETS OF THE DEBTORS INTERIORS PLASTICS GROUP FREE AND CLEAR OF LIENS, CLAIMS, ENCUMBRANCES AND INTERESTS AND RELATED RELIEF QCR Tech LLC, n/k/a QC Tech LLC ( QCR ), by and through its attorneys Seyburn, Kahn, Ginn, Bess & Serlin, brings this Amended Objection to the Cure Amounts listed for QCR in the Order Approving Bidding Procedures, Sale of Certain Assets of the Debtors Interiors Plastics Group Free and Clear of Liens, Claims, Encumbrances and Interests and related relief and in support of its Amended Objection states as follows: 1. On April 2, 2007, the Debtors filed a Motion to approve bidding procedures and (Jointly Administered) Case No: 05-55927-SWR Chapter 11 Hon. Stephen W. Rhodes

schedule a sale hearing relating to the sale of certain assets of the Interiors Plastics Group as docket number 4408 (the Motion ). Exhibit A to the Notice was served on April 26, 2007, and was filed as docket number 4670 (the Original Notice ). The Original Notice was later

corrected and served on May 4, 2007, as an attachment to the Notice of Clerical Error Regarding Assumed Agreement Related to the Debtors Interiors Plastics Group Sale, (the Amended

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Notice ). The list of contracts to be assumed varies substantially from the Original Notice to the Amended Notice, and QCR is uncertain which contracts the Debtor intends to assume. 2. 3. The Court entered an order granting the Motion as docket number 4532. Both the Original Notice and the Amended Notice (hereafter collectively referred

to as the Assumption List ) list QCR as a Counterparty, and reference a number of purchase orders to be assumed by the purchaser of the assets of the Contracts ). 4. The Assumption List indicates that there are no unpaid balances due on the QCR Debtor (hereafter the QCR

Contracts (each is shown on the Assumption List as $0 Cure Amount). 5. The books and records of QCR indicate substantial unpaid balances on the QCR

Contracts, or substantial work in progress which will be payable upon completion of testing of the tools involved. Attached as Exhibit A to this Amended Objection is a list of the QCR Contracts which QCR believes the Debtor intends to assume and assign, including the cure amounts that QCR believes are due on each of those contracts as of May 11, 2007. Of the amounts shown, $567,460 has been invoiced and $127,960 is pending for work in process. 6. Exhibit A also lists six additional outstanding purchase orders (Nos. 65832,

65892, 66590, 66591, 66606 and 66680, hereafter the Other QCR Contracts ). QCR believes the Debtor does not intend to assume these contracts, but is unable to verify that information. 7. Attached as Exhibit B is the affidavit of Craig Capece, President of QC Tech,

LLC. (f/k/a QCR Tech, LLC), verifying that Exhibit A is a true, accurate and complete report of the cure amounts on the QCR Contracts and the Other QCR Contracts. 8. To the extent any of the contracts listed on Exhibit A are to be assumed, QCR has

not been given any adequate assurance of future performance under the contracts by the stalking

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horse bidder (or the successful purchaser) for the assets to be purchased, in violation of 11 USC 365(b). WHEREFORE, QCR respectfully requests that confirmation of the sale be denied, or assumption of the QCR Contracts be prohibited unless and until: a. Provision is made in the Order Confirming Sale and the Asset Purchase

Agreement for payment in full, either before, at, or promptly after closing of the sale, for payment of all of the amounts due or to become due to QCR on the QCR Contracts, in accordance with attached Exhibits A and B; b. The Debtor has verified the contracts with QCR it intends to assume and those it

does not intend to assume; and c. QCR has been provided with adequate assurance that the successful purchaser at

the sale of the assets will be able to perform under the QCR Contracts.

SEYBURN, KAHN, GINN, BESS AND SERLIN, P.C.

By:

/s/ Leslie Stein (P31922) Attorneys for QCR Tech, LLC 2000 Town Center, Suite 1500 Southfield, MI 48075-1195 (248) 353-7620

Dated: May 15, 2007

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