IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MICHIGAN (Southern Division) IN RE: ) ) COLLINS &

AIKMAN CORPORATION, et al. ) ) Debtors. ) ) __________________________________________)

Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered)

FIRST AMENDED VERIFIED STATEMENT OF WILMER CUTLER PICKERING HALE AND DORR LLP PURSUANT TO BANKRUPTCY RULE 2019 TO: THE HONORABLE STEVEN W. RHODES UNITED STATES BANKRUPTCY JUDGE:

Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedures, Andrew N. Goldman, Esq., a senior partner with the law firm of Wilmer Cutler Pickering Hale and Dorr LLP (WilmerHale), located at 399 Park Avenue, New York, New York 10022, hereby discloses that WilmerHale represents or has represented the following parties-in-interest or creditors in the above captioned chapter 11 cases (collectively, the Debtors): 1. On May 14, 2007, Bose Corporation (Bose), located at The Mountain,

Framingham MA 01701, engaged WilmerHale to represent it in connection with litigation filed by the Debtors against Bose (Adv. Pro. 07-04815-SWR). The complaint contains counts for alleged preferential transfers and fraudulent conveyances. At this initial stage, the claims and counterclaims of Bose against the Debtors are under review. 2. WilmerHale currently represents David A. Stockman, whose address is 55

Railroad Avenue, Greenwich CT, 06830. Mr. Stockman was a director of Collins & Aikman Corporation (C&A) from February 2001 through May 12, 2005 and was C&As Chief

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Executive Officer from August 11, 2003 through May 12, 2005. From time to time, Mr. Stockman may have served as an officer and/or director of C&As debtor and non-debtor affiliates. He also previously held various positions with Heartland Industrial Partners, L.P. and or certain of its affiliates. As of the date Debtors filed for chapter 11 relief, Mr. Stockman directly owned approximately 320,000 shares of C&As common stock. Mr. Stockman has filed a proof of claim against C&A (as to C&A, Proof of Claim No. 6878) and each of its debtor affiliates, asserting liquidated and unliquidated claims regarding amounts owed to him. 3. On May 10, 2007, WilmerHale and Lisa S. Gretchko of Howard & Howard

Attorneys, P.C. (local counsel) filed a Notice of Appearance (Dkt No. 5272) as attorneys for Mr. Stockman. 4. For a brief period at the beginning of these chapter 11 cases, WilmerHale

represented Chanin Capital Partners LLC (Chanin), located at 11150 Santa Monica Boulevard, 6th Floor, Los Angeles, CA 90025. Specifically, in mid-July 2005promptly after the Official Committee of Unsecured Creditors (the Committee) had selected Chanin as financial advisorChanin engaged WilmerHale to represent it in connection with the negotiation and execution of Chanins engagement letter and retention application/order. Chanin is a longstanding client of WilmerHale, and WilmerHale has represented Chanin in the same capacity in many other chapter 11 cases. Between July and early September 2005, WilmerHale, provided the following services on behalf of Chanin: (a) negotiating the terms of Chanins engagement letter and indemnification protections with Counsel to the Committee; (b) holding discussions with Counsel to the Prepetition Lenders concerning Chanins retention and scope of proposed services; (c) resolving the United States Trustees concerns; and (d) negotiating Chanins retention order.

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5.

Chanins retention application was approved by the Court on Sept. 16, 2005 (Dkt

No. 1184). At that point, WilmerHale concluded its representation of Chanin as denoted above and closed its files and records on the matter. 6. On June 28, 2007, Chanin re-engaged WilmerHale to represent it in connection

with the review of professionals fees to be performed by the fee examiner appointed in these cases. WilmerHale will also represent Chanin with respect to its final fee application in these cases and any objections with respect thereto. 7. Each of Bose, Mr. Stockman, and Chanin has been apprised of the foregoing and

has consented to WilmerHales multiple representations in these cases. 8. I respectfully disclose the foregoing to the Court.

I SOLEMNLY DECLARE AND AFFIRM UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. DATE: July 3, 2007 Respectfully submitted, /s/ Andrew N. Goldman Andrew N. Goldman, Esquire (AG 1010) WILMER CUTLER PICKERING HALE AND DORR LLP 399 Park Avenue New York, New York 10022 Phone: (212) 230-8836 Fax: (212) 230-8888 andrew.goldman@wilmerhale.com By:

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