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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 AP Services, LLC, in its capacities as Liquidation Trustee and Disbursing Agent 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

PROPOSED AGENDA FOR MARCH 28, 2012 OMNIBUS HEARING1

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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Time and Date of Hearing: Location of Hearing:

March 28, 2012 at 10:00 a.m. (prevailing Eastern Time)

Hon. Shelley C. Chapman United States Bankruptcy Court for the Southern District of New York Courtroom No. 610 One Bowling Green Alexander Hamilton Custom House New York, New York 10004 A copy of each pleading can be viewed on the Courts website at ecf.nysb.uscourts.gov and at the website of the Debtors notice and claims agent, Omni Management Group, LLC (Omni), at www.omnimgt.com/innkeepers. Further information may be obtained by calling Omni at (866) 989-6147.

Copies of Motions:

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Uncontested Matters A. Stipulation and Agreed Order Resolving Debtors Objections to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc. and Lehman ALI, Inc. Against Grand Prix Holdings LLC [Docket No. 2364] Related Filings: 1. 2. 3. Debtors Objection to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc. Against Grand Prix Holdings LLC [Docket No. 1865] Debtors Objection to Guaranty Claim Asserted by Lehman ALI, Inc. Against Grand Prix Holdings LLC [Docket No. 1866] Response of SASCO 2008-C2, LLC to Debtors Objection to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc. Against Grand Prix Holdings, LLC and Memorandum In Support of Motion for Summary Judgment Regarding Claim Objection [Docket No. 2305] SASCO 2008-C2, LLCs Motion for Summary Judgment with Respect to Debtors Objection to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc., Against Grand Prix Holdings, LLC [Docket No. 2306] Trustees Reply to Response of SASCO 2008-C2, LLC to Debtors Objection to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc. Against Grand Prix Holdings, LLC and Memorandum in Support of Motion for Summary Judgment Regarding Claim Objection [Docket No. 2336]

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Status: This matter will proceed on an uncontested basis. B. Stipulation and Agreed Order Resolving Debtors Objection to Guaranty Claim Asserted by Five Mile Capital Real Estate Advisors LLC Against Grand Prix Holdings LLC [Docket No. 2332] Related Filings: 1. 2. Debtors Objection to Guaranty Claim Asserted by Midland Loan Services, Inc. Against Grand Prix Holdings LLC [Docket No. 1867] Response of Five Mile Capital Real Estate Advisors LLC to the Debtors Objection to Guaranty Claim Asserted by Midland Loan Services, Inc. Against Grand Prix Holdings LLC [Docket No. 2308]

Status: This matter will proceed on an uncontested basis.

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C.

Tenth Omnibus Objection to Claims (Compound Claims to be Reclassified, No Liability Claims, Equity Interest Claims, Amended and Superseded Claims and Duplicative Claims [Docket No. 2294] Declaration of Todd Brents in Support of Debtors Tenth Omnibus Objection to (Compound Claims to be Reclassified, No Liability Claims, Equity Interest Claims, Amended and Superseded Claims and Duplicative Claims) [Docket No. 2295] Responses Received: 1. 2. City and County of Denvers Response to Debtors Tenth Omnibus Objection [Docket No. 2321] Response by Commissioner of Massachusetts Department of Revenue to the Tenth Omnibus Objection to Claims [Docket No. 2354]

Replies Received: In addition to the above-referenced responses, the Liquidation Trustee also received additional informal replies from several claimants that have also since been resolved. Status: The City and County of Denvers response has been adjourned to the next scheduled omnibus hearing. This matter will otherwise proceed on an uncontested basis. D. Disbursing Agents Motion for Order Identifying Allowed Fixed/Floating General Unsecured Claims for Distribution Purposes [Docket No. 2296] Responses Received: None Replies Received: None Status: This matter will proceed on an uncontested basis. Contested Matter A. Motion of Gareth Tooly for Allowance of Claim [Docket No. 1908] Additional Information re Motion of Gareth Tooly for Allowance of Claim [Docket No. 1909] Responses Received: 1. Objection to Motion of Gareth Tooly [Docket No. 2297]

Replies Received: None Status: This matter will proceed on a contested basis.

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New York, New York Dated: March 27, 2012

/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 AP Services, LLC, in its capacities as Liquidation Trustee and Disbursing Agent

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