UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

In re: INNKEEPERS USA TRUST, et al., Debtors.

) Chapter 11
)

) Case No. 10-13800 (SCC)

)

) (Jointly Administered)
)

VERIFIED STATEMENT PURSUANT TO RULE 2019(a) OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE
Pursuant to the provisions of Rule 2019(a) of the Federal Rules of Bankruptcy Procedure, Russell R. Johnson ill of the Law Finn ofRussell R. Johnson ill, PLC files this Verified Statement of his finn's multiple representations in this case: I. The name and address of the creditors represented by the Law Finn of Russell R.

Johnson lll, PLC are:

A.

Virginia Electric and Power Company d/b/a Dominion Virginia Power Attn: Sherry Ward 70 I East Cary Street Richmond, VA 23219 Florida Power Corp. d/b/a Progress Energy Florida Attn: Elaine A. McCallister 160 Rush St. WWJ Raleigh, NC 27603 Georgia Power Company Attn: Jim Maynard 2500 Patrick Henry Parkway McDonough, GA 30253

B.

C.

D.

San Diego Gas & Electric Company Attn: Nicoma A. Jackson Bankruptcy Specialist 8326 Century Park Court San Diego, CA 92123 Southern California Gas Company Attn: Carmen Ortega P.O. Box 30337 Los Angeles, CA 30337 Jersey Central Power & Light Company Attn: Christine Weber, Esq. FirstEnergy Corp. 76 S. Main St., A-G0-15 Akron, OH 44308 Rockland Electric, a subsidiary of Orange and Rockland Utilities, Inc. Attn: Leon Z. Mener, Esq. 4 Irving Place - Room 1875S New York, NY 10003 The Connecticut Light and Power Company Attn: HonorS. Heath, Esq. Northeast Utilities Service Company 107 Selden Street Berlin, CT 06037 New York State Electric and Gas Corporation Attn: Mary C. Haskell 18 Link Drive Binghamton, NY 13904 Public Service Electric and Gas Company Attn: Suzanne Klar, Esq. 80 Park Plaza, T5D Newark, NJ 07102-0570 Southern California Edison Company Attn: Laura A. Meyerson Senior Attorney Southern California Edison Company 2244 Walnut Grove Ave., 3rd Floor Rosemead, CA 91770
2

E.

F.

G.

H.

I.

J.

K.

2.

The nature and the amount of claims (interests) and the times of acquisition

thereof are as follows: (a) Virginia Electric and Power Company d/b/a Dominion Virginia Power, Georgia

Power Company, Jersey Central Power & Light Company, Southern California Edison Company, San Diego Gas & Electric Company, New York State Electric and Gas Corporation, Public Service Electric and Gas Company, Southern California Gas Company, Rockland Electric, a subsidiary of Orange and Rockland Utilities, Inc., and The Connecticut Light and Power Company have unsecured claims against one or more of the above-referenced Debtors arising from pre-petition utility usage. (b) Both Virginia Electric and Power Company, d/b/a Dominion Virginia Power and

Florida Power Corporation d/b/a Progress Energy Florida held surety bonds on the Debtors' prepetition accounts. (c) For more information regarding the foregoing utility companies' interests and

claims in this case, refer to the Objection of Certain Utility Companies to the Debtors' Motion

For Entry of an Order Determining Adequate Assurance of Payment For Future Utility Services
filed in connection with this pleading. 3. The Law Firm ofRussell R. Johnson III, PLC was retained to represent the

foregoing creditors in July 2010.

Russell R. Johnson ill appeared before me this 1ft\ day of August 2010, and acknowledged that the representations in the foregoing statement are true to the best of his knowledge, information and belief. NOTARY PUBLIC

My commission expires: \JQJ

3q 2.v1 ::>

CHRISTIN CLARKE MCDUFFIE

Notary Public Commonwealth of Virginia

294855 My Commtaalon Expires Nov 30 ?013