UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al.,1 Debtors.

) ) ) ) ) ) ) Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

ORDER GRANTING DEBTORS EX PARTE MOTION (A) FOR AN EXPEDITED HEARING AND (B) TO SHORTEN THE NOTICE PERIOD WITH RESPECT TO THE DEBTORS MOTION FOR ENTRY OF AN ORDER EXTENDING TIME TO FILE NOTICES OF REMOVAL OF ACTIONS1 Upon the ex parte motion (the Motion)2 of the above-captioned debtors (collectively, the Debtors) for the entry of an order (this Order) (a) setting the hearing date to consider the Debtors Motion for Entry of an Order Extending Time to File Notices of Removal of Action (the Removal Motion) for October 14, 2010, and (b) shortening the notice period with respect to the Removal Motion, all as more fully set forth in the Motion; it appearing that the relief requested is in the best interests of the Debtors estates, their creditors, and other parties in interest; the Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); venue being proper before this court pursuant to 28 U.S.C. 1408 and 1409; notice of the Motion having been adequate and

The list of Debtors in these Chapter 11 Cases along with the last four digits of each Debtors federal tax identification number can be found by visiting the Debtors restructuring website at www.omnimgt.com/innkeepers or by contacting Omni Management Group, LLC at Innkeepers USA Trust c/o Omni Management Group, LLC, 16161 Ventura Boulevard, Suite C, PMB 606, Encino, California 91436. The location of the Debtors corporate headquarters and the service address for their affiliates is: c/o Innkeepers USA, 340 Royal Poinciana Way, Suite 306, Palm Beach, Florida 33480. All capitalized terms used but otherwise not defined herein shall have the meanings set forth in the Motion.

K&E 17796913

appropriate under the circumstances; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. 2. The Motion is granted to the extent provided herein. The 14-day notice period, otherwise applicable to a hearing for approval of the

Removal Motion, is shortened to a 10-day notice period, pursuant to Bankruptcy Rules 9006 and 9007 and Local Bankruptcy Rules 9006-1 and 9077-1, so that the hearing to consider the Removal Motion shall be held on October 14, 2010 at 10:00 a.m. prevailing Eastern Time, or as soon thereafter as the Debtors may be heard, before the Honorable Shelley C. Chapman, United States Bankruptcy Judge, in Courtroom No. 610 of the United States Bankruptcy Court for the Southern District of New York, Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408. 3. The deadline for the service and filing of objections to the Removal Motion shall

be October 13, 2010 at 12:00 p.m. prevailing Eastern Time. 4. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 5. All time periods set forth in this Order shall be calculated in accordance with

Bankruptcy Rule 9006(a). 6. The Debtors are authorized to take all actions necessary to effectuate the relief

granted pursuant to this Order in accordance with the Motion. 7. The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order. New York, New York Date: October 4, 2010 /s/Shelley C. Chapman United States Bankruptcy Judge

2
K&E 17796913