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

ORDER UNSEALING OBJECTIONS AND OTHER REPLIES TO MOTION TO ASSUME PLAN SUPPORT AGREEMENT Upon the Courts sua sponte motion (the Motion) for the entry of an order (this Order) requiring certain parties that filed an objection or reply (as applicable) to the motion of the above-captioned debtors and debtors in possession (collectively, the Debtors) motion to assume the Plan Support Agreement [Docket No. 15] (Motion to Assume the Plan Support Agreement) in accordance with the Order Authorizing Parties to the August 16, 2010 Protective Order to File Objections or Other Replies to Motion to Assume Plan Support Agreement Under Seal & for Other Relief [Docket No. 273] (the Seal Order) to unseal such objections and replies and any supporting exhibits; and the Court having found that the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; and the Court having found that this is a core proceeding pursuant to 28 U.S.C. 157(b)(2); and the Court having found that venue of this proceeding and the Motion in this District is proper pursuant to 28 U.S.C. 1408 and 1409; and the Court having found that the relief is in the best interests of the Debtors estates, their creditors, and other parties in interest; and the Court having found that notice of this Motion was appropriate under the particular circumstances and that no other further notice need be given; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT:

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All documents, including, objections, replies, and supporting exhibits filed under

seal in accordance with the Seal Order (including, without limitation, Docket Numbers 256, 260, 279, 280, 340, and 341) are hereby unsealed; provided, however, that the supporting exhibits to Marriott International, Inc.s Limited Objection to and Reservation of Rights Regarding Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 246] (the Marriott Reservation of Rights) shall remain sealed. 2. The parties shall promptly file unsealed versions of objections, replies, and any

supporting exhibits thereto to the Motion to Assume the Plan Support Agreement; provided, however, that the supporting exhibits to the Marriott Reservation of Rights shall not be filed. 3. Each party filing a document in accordance with paragraph 2 hereof shall serve

via electronic mail and overnight mail an appropriate notice (the Unsealing Notice) together with the objections and replies (as applicable), but not the supporting exhibits, informing the appropriate parties of the filing of the objections, replies, and supporting exhibits and that the objections, replies, and supporting exhibits may be obtained (a) free of charge by (i) visiting the Debtors restructuring website at www.omnimgt.com/innkeepers or (ii) 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; or (b) by visiting the Courts website at http://www.nysb.uscourts.gov in accordance with the procedures and fees set forth therein. Service of (a) the Unsealing Notice in lieu of the supporting exhibits and (b) the objections or replies (as applicable) shall constitute sufficient and appropriate notice under the particular circumstances.

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The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order. New York, New York Date: August 31, 2010 /s/Shelley C. Chapman THE HONORABLE SHELLEY C. CHAPMAN UNITED STATES BANKRUPTCY JUDGE

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