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

CORPORATION, et al. Debtors. _________________________________________________/ Case No. 05-55927 (SWR) Chapter 11 Jointly Administered Honorable Steven W. Rhodes

VERIFIED STATEMENT OF ALLARD & FISH, P.C. PURSUANT TO BANKRUPTCY RULE 2019(a) Katherine R. Catanese, being first duly sworn, deposes and says that she is an associate attorney with the firm of Allard & Fish, P.C. (A&F); that she is authorized to make this Verified Statement on behalf of A&F; and that the following Verified Statement is true and accurate to the best of her knowledge, information and belief: 1. A&F represents K.J. Egleston and the class of investors that he seeks to represent

(Egelston), whose address is c/o Thomas H. Burt, Esq., Wolf, Haldenstein, Adler, Freeman, & Herz, LLP, 270 Madison Avenue, New York, NY, 10016, as bankruptcy co-counsel in connection with opposing motions by the Debtor to stay litigation pending in the United States District Court for the Southern District of New York brought by Egelston et. al., as well as other cases that have been consolidated therewith, as well as matters relating to certain directors and officers liability insurance policies. A&F also represents Egelston in adversary proceeding number 06-4211, captioned Collins & Aikman Corp., et al. v. K.J. Egelston, et. al. A&Fs employment on behalf of Egelston was arranged by Mr. Burt, Esq.

0W[;'%5

0555927070521000000000001

!r

2.

A&F represents Elite Tool, Inc. (Elite), whose address is c/o Michael McNutt,

311 S. Cool Springs Rd., OFallon, MO 63366, a potential preference defendant in the Collins & Aikman bankruptcy case. Elite engaged A&F to give it advice as to its preference defenses and to assist in an adversary proceeding if one were filed. To date, A&F has given Elite advice regarding preference defenses available to it and on a future course of action. A&Fs employment on behalf of Elite was arranged by Michael McNutt, Elites President. Collins & Aikman contends that it is owed $16,187 by Elite for alleged preferential transfers. 3. A&F represents certain underwriters of Lloyds, London (Lloyds), whose

address is c/o Peter Ackerman, Esq., Duane Morris, LLP, 633 West Fifth Street, suite 4600, Los Angeles, California, 90071, an interested party to the sale of Collins & Aikmans plastics business. A&Fs employment on behalf of Lloyds was arranged through a referral by John Collen, Esq. of Duane Morris. 4. A&F represents JVIS-USA, LLC, (JVIS), whose address is 42500 Mound

Road, Sterling Heights, Michigan, 48314. A&F was employed to file an objection to the sale of Collins & Aikmans plastics business. A&Fs employment on behalf of JVIS was arranged through Timothy Bradley, its in-house counsel. 5. A&F has represented W.C. Black and Sons, Inc. (W.C.), whose address is c/o

Jason Black, 4924 Allen Road East, Charlotte, North Carolina, 28269. A&F was retained to file a motion to lift stay in order to permit a lien foreclosure on real property in North Carolina to proceed. This representation has been completed, and A&Fs file with regard to this matter is now closed.

6.

A&F has represented W9/LWS Real Estate Limited Partnership (W9), whose

address is c/o David S. Melin, Esq., Rayburn Cooper & Durham, P.A., 227 West Trade Street, Suite 1200, Charlotte, North Carolina, 28202. A&F was retained to file a limited objection to a motion filed by one of the debtors. This representation has been completed, and A&Fs file with regard to this matter is now closed. 7. A&F has represented David Seibert (Mr. Seibert), whose address is 1258 17th

Street, Marysville, Michigan, 48040. This representation has been completed, and A&Fs file with regard to this matter is now closed. 8. A&F has represented BPV Lowell, LLC (BPV), whose address is c/o Karl Frey,

Vespera, 600 Summer Street, Stamford, Connecticut, 06901. A&F was retained to represent BPV with regard to collection of lease damages. This representation has been completed, and A&Fs file with regard to this matter is now closed. 9. A&F has represented Hayoshi of America, Inc. (Hayoshi), whose address is c/o

Rein Krammer, Esq., Masuda, Funai, Eifert and Mitchell, Ltd., 203 N. Lasalle Street, Suite 2500, Chicago, Illinois, 60601-1262. A&F was retained to represent Hayoshi as local counsel with regard to filing a motion to lift stay. This representation has been completed, and A&Fs file with regard to this matter is now closed. 10. A&F has represented Northern Trust Bank of America N.A. as trustee

(Northern), whose address is c/o Wesley H. Avery, Esq., Musick, Peeler, and Garrett, L.L.P., One Wilshire Boulevard, Los Angeles, California, 90017-3321. A&F was retained to represent Northern with regard to adversary proceeding number 06-4435-SWR, captioned Collins &

Aikman v. Northern Trust Bank of California. This representation has been competed, and A&Fs file with regard to this matter is now closed. Further affiant sayeth not. ALLARD & FISH, P.C.

/S/Katherine R. Catanese 2600 Buhl Building 535 Griswold Detroit, MI 48266 (313) 961-6141 kcatanese@allardfishpc.com P67542 Dated: May 21, 2007 Subscribed to and sworn before me this 21st day of May, 2007 /S/Regina Drouillard Notary Public, Wayne County, Michigan My commission expires: Jan. 19, 2011 Acting in Wayne County
U:\31\043\pld\Statement Pursuant to 2019.doc