Objection Deadline: May 20, 2011 at 4:00 p.m.

(ET)

James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Todd M. Schwartz (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession 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

NOTICE OF MONTHLY APPLICATION OF KIRKLAND & ELLIS LLP FOR COMPENSATION FOR SERVICES AND REIMBURSEMENT OF EXPENSES AS ATTORNEYS FOR THE DEBTORS AND DEBTORS IN POSSESSION FOR THE PERIOD FROM MARCH 1, 2011 THROUGH MARCH 31, 20111

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.

K&E 18927373

PLEASE TAKE NOTICE that, on April 29, 2011, Kirkland & Ellis LLP (K&E) filed the above-referenced application (the Application).2 The Application is filed with the Court at Docket No. 1169 and may be obtained (a) from the Debtors Notice and Claims Agent by: (i) visiting http://www.omnimgt.com/innkeepers; (ii) writing to Innkeepers USA Trust c/o Omni Management Group, LLC, 16161 Ventura Boulevard, Suite C, PMB 606, Encino, California, 91436; or (iii) calling (866) 989-6147, or (b) for a fee via PACER at http://www.nysb.uscourts.gov. A copy of the Application can also be obtained upon written request to K&E. PLEASE TAKE FURTHER NOTICE that any responses or objections to the Application, which may only be filed by a Notice Party (as defined in the Interim Compensation Order [Docket No. 189]): must be in writing; shall conform to the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), all General Orders and Local Rules for the United States Bankruptcy Court for the Southern District of New York, and the Interim Compensation Order; shall be filed with the Bankruptcy Court electronically by registered users of the Bankruptcy Courts case filing system (the Users Manual for the Electronic Case Filing System can be found at www.nysb.uscourts.gov, the official website for the Bankruptcy Court); and shall be served so as to be actually received no later than May 20, 2011 at 4:00 p.m. prevailing Eastern Time (the Objection Deadline) by: (a) the Debtors; (b) the Office of the United States Trustee for the Southern District of New York; (c) counsel to the Official Committee of Unsecured Creditors; (d) counsel to Midland Loan Services, Inc.; and (e) counsel to Certain Prepetition Lenders (each as defined in the Interim Compensation Order). PLEASE TAKE FURTHER NOTICE that payment of the amounts requested in the Application shall be as set forth in the Interim Compensation Order.
2

Capitalized terms used but not defined herein have the meanings ascribed to them in the Application.

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New York, New York Dated: April 29, 2011

/s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Todd M. Schwartz (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession

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