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

Corp., et al, Debtors. ______________________________/ RIVAS INC. 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 Rivas, Inc., a Michigan corporation ( Rivas), by and through its attorneys Seyburn, Kahn, Ginn, Bess & Serlin, brings this Amended Objection to the Cure Amounts listed for Rivas 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

amended 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 changes from the Original Notice to the Amended Notice, and Rivas is uncertain which contracts the Debtor intends to assume and assign. 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 Rivas as a Counterparty, and reference a number of purchase orders to be assumed by the Debtor and assigned to the purchaser of the assets of the Debtor (hereafter the Rivas Pre-Petition Contracts ). 4. On information and belief, there are also post-petition contracts which the Debtor

proposes to assign to the purchaser, but which it has not identified to Rivas. 5. The Assumption List indicates that there are no unpaid balances due on the Rivas

Pre-Petition Contracts (each is shown on the Assumption List as $0 Cure Amount). 6. The books and records of Rivas indicate unpaid balances on the Rivas Pre-

Petition Contracts, or tooling work which will be payable upon completion of PPAP testing. Attached as Exhibit A to this Amended Objection is a list of the Rivas Pre-Petition Contracts which Rivas believes the Debtor intends to assume and assign, including the cure amounts that Rivas believes were due on each of those contracts as of June 14, 2007. Obviously, the amounts due on PO #71148 (a blanket purchase order) will vary from time to time as parts are released and delivered and payments are made. 7. Attached as Exhibit B is the affidavit of Peer Larson, Vice President of Rivas,

verifying that Exhibit A is a true, accurate and complete report of the cure amounts on the Rivas Pre-Petition Contracts. 8. To the extent any of the contracts listed on Exhibit A are to be assumed, Rivas 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). 9. To the extent any post-petition contracts are intended to be assigned, they have

not been identified to Rivas. And, to the extent post petition contracts will be assigned, neither the Debtor nor the prospective purchaser have provided adequate assurance of ability to duly perform all remaining obligations on any such post-petition contracts, as requested in the e-mail to Paul Wierbicki, one of the Debtor s attorneys, attached as Exhibit C. MCLA 440.2210 and 440.2609 entitle the seller to such assurances if a contract is assigned, or if reasonable grounds for insecurity exist for non-payment by the existing buyer (as they may in this case, since the entire business line to which the post-petition contracts relate is being sold). WHEREFORE, Rivas respectfully requests that confirmation of the sale be denied, or assumption and assignment of the Rivas Pre-Petition Contracts and assignment of any postpetition 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 Rivas on the Rivas Pre-Petition Contracts which the Debtor intends to assume and assign, in accordance with attached Exhibits A and B; b. The Debtor has verified the Rivas Pre-Petition Contracts it intends to assume and

assign and the post-petition contracts with Rivas it intends to assign, and provided a complete list of contracts which will not be assigned (whether pre or post petition); and c. Rivas has been provided with adequate assurance that the Debtor will duly

perform any of its remaining obligations under post-petition contracts and the prospective

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purchaser of the North American Plastics division will be able to duly perform under the Rivas Pre-Petition Contracts and the post petition contracts being assigned.

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

By:

/s/ Leslie Stein (P31922) Attorneys for Rivas, Inc. 2000 Town Center, Suite 1500 Southfield, MI 48075-1195 (248) 353-7620

Dated: June 20, 2007

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EXHIBIT A RIVAS, INC. 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 Description of Contract C&A Tooling PO No. 71148 C&A Tooling PO No. 62942 C&A Tooling PO No. 59016 C&A Tooling PO No. 84625 Counter Party Rivas, Inc. Rivas, Inc. Rivas, Inc. Rivas, Inc. Cure Amount $5,647.95* $33,800.00 ** $1,137.80 $0.00***

* Amount listed is current through June 14, 2007, but is subject to change - this is an open blanket purchase order. ** This amount has not been invoiced, although all of Rivas work is complete, pending final PPAP approval not within Rivas control. ***This is a spot purchase order for expandable packaging with no open balance, but additional packaging will be required and another spot purchase order should by issued.

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