UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

In re: COLLINS & AIKMAN CORPORATION, et al.1, Debtors.

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

STIPULATION BETWEEN COLLINS & AIKMAN POSTCONSUMMATION TRUST, COLLINS & AIKMAN LITIGATION TRUST, AND EL PASO NATURAL GAS COMPANY This Stipulation is entered into by the Collins & Aikman Post-Consummation Trust, the Collins & Aikman Litigation Trust (collectively the Trusts), as successors to the abovecaptioned Debtors (collectively, the Debtors) pursuant to the First Amended Joint Plan of Reorganization of Collins & Aikman Corporation and its Debtor Subsidiaries as confirmed by order of the Bankruptcy Court, and El Paso Natural Gas Company (El Paso) (collectively, the Trusts and El Paso shall be referred to as the Parties), by their undersigned counsel.
The Debtors in the proposed jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc.; Becker Group, LLC (d/b/a Collins & Aikman Premier Mold); Brut Plastics, Inc.; Collins & Aikman (Gibraltar) Limited; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation); Collins & Aikman Asset Services, Inc.; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.); Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.); Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.); Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.); Collins & Aikman Automotive International, Inc.; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.); Collins & Aikman Automotive Mats, LLC; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.); Collins & Aikman Automotive Services, LLC; Collins & Aikman Canada Domestic Holding Company; Collins & Aikman Carpet & Acoustics (MI), Inc.; Collins & Aikman Carpet & Acoustics (TN), Inc.; Collins & Aikman Development Company; Collins & Aikman Europe, Inc.; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.); Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.); Collins & Aikman Interiors, Inc.; Collins & Aikman International Corporation; Collins &.Aikman Plastics, Inc.; Collins & Aikman Products Co.; Collins & Aikman Properties, Inc.; Comet Acoustics, Inc.; CW Management Corporation; Dura Convertible Systems, Inc.; Gamble Development Company; JPS Automotive, Inc. (d/b/a PACJ, Inc.); New Baltimore Holdings, LLC; Owosso Thermal Forming, LLC; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.); Wickes Asset Management, Inc.; and Wickes Manufacturing Company.
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WHEREAS, on May 17, 2005 (the Petition Date), the Debtors filed petitions for relief under Chapter 11 of Title 11 of the United States Code in the United States Bankruptcy Court for the Eastern District of Michigan (the Bankruptcy Court); WHEREAS, El Paso filed claim 6851 alleging, inter alia, a general unsecured claim in the amount of $2,217,084.90 (the Claim); WHEREAS, on June 27, 2008 the Collins & Aikman Litigation Trust filed its FortyNinth Omnibus Objection to Claims, and the Claim was a subject of that Objection; WHEREAS, in an effort to avoid the risks and expenses of litigation, the Parties have entered into negotiations to resolve the Claim; NOW, THEREFORE, in consideration of the mutual promises contained herein, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, IT IS STIPULATED AND AGREED THAT: 1. $26,666.66. 2. To the extent that the Trusts hold any interest in Cross Country Development The Claim will be allowed as a general unsecured claim for the amount of

LLC, the Trusts hereby agree to transfer half of that interest to El Paso and the other half of that interest to Wilson Sporting Goods Company (Wilson). 3. The Collins & Aikman Litigation Trusts Forty-Ninth Omnibus Objection to

Claims is hereby withdrawn only with regard to El Pasos Claim. 4. To the extent any distributions are made on the Claim, such distributions will be

made pursuant to the terms of the First Amended Joint Plan of Collins & Aikman Corporation and Its Debtor Subsidiaries, dated July 9, 2007, as confirmed by the Order Confirming the First

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Amended Joint Plan of Collins & Aikman Corporation and Its Debtor Subsidiaries, entered on July 18, 2007. 5. The Debtors notice and claims agent, Kurtzman Carson Consultants, LLC, is

authorized to take all actions necessary to effect this stipulation. 6. By agreeing to enter into this Stipulation, the Parties shall not be deemed to have

waived any right or remedy afforded to them under the Bankruptcy Code or otherwise, except as provided in this Stipulation. 7. This Stipulation may not be modified, altered, amended or vacated without the

written consent of all parties hereto. Any such modification, alteration, amendment or vacation, in whole or in part, shall be subject to the approval of the Bankruptcy Court. The Bankruptcy Court shall retain jurisdiction to resolve any disputes or controversies arising from or related to this Stipulation. 8. A proposed order, consistent with the terms of this Stipulation, shall be submitted

to the Bankruptcy Court immediately following the filing of this Stipulation. SO STIPULATED, APPROVED AS TO FORM AND CONTENT:

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BOYLE BURDETT /s/ H. William Burdett, Jr w/consent) H. William Burdett, Jr. (P63185) 14950 East Jefferson, Suite 200 Grosse Pointe Park, Michigan 48230 (313) 344-4000 (313) 344-4001 (facsimile) Burdett@boyleburdett.com Attorneys for Collins & Aikman PostConfirmation Trust; and the Litigation Trust By:

CLARK HILL PLC By: /s/ Jami A. Statham Joel D. Applebaum (P36774) Jami A. Statham (P69747) 500 Woodward Avenue, Suite 3500 Detroit, Michigan 48226 (313) 965-8300 (313) 965-8252 (facsimile) japplebaum@clarkhill.com Attorney for El Paso

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