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. 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 HEARING REGARDING SECOND INTERIM APPLICATIONS FOR COMPENSATION FOR FEES AND REIMBURSEMENT OF EXPENSES OF PROFESSIONALS1

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.

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PLEASE TAKE NOTICE that, pursuant to the Order Authorizing the Establishment of Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and Official Committee Members, entered August 12, 2010 [Docket No. 189]

(the Interim Compensation Order),2 the parties set forth below filed Interim Applications.

Party Filing Interim Application Morrison & Foerster LLP Fried, Frank, Harris, Shriver & Jacobson LLP Moelis & Company, LLC Jefferies & Company, Inc. Kirkland & Ellis LLP

Date of Filing/Service Docket No. May 13, 2011 May 13, 2011 May 13, 2011 May 16, 2011 May 16, 2011 1375 1377 1391 1401 1403

PLEASE TAKE FURTHER NOTICE that a hearing for the Interim Applications will be held 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 (the Court), Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408, on June 7, 2011 at 2:00 p.m. prevailing Eastern Time or such other time as counsel may be heard. PLEASE TAKE FURTHER NOTICE that any responses or objections to the Interim Applications: 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
2

Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Interim Compensation Order.

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www.nysb.uscourts.gov, the official website for the Bankruptcy Court); and shall be served so as to be actually received no later than 14 days from the date of filing and service (or the next business day) at 4:00 p.m. prevailing Eastern Time 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.; (e) counsel to Certain Prepetition Lenders (each as defined in the Interim Compensation Order); and (f) the respective Professional whose Application is the subject of the response or objection.

New York, New York Dated: May 16, 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. 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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