HAYNES AND BOONE, LLP 1221 Avenue of the Americas, 26th Floor New York, New York 10020

Telephone: (212) 659-7300 Facsimile: (212) 884-8211 Lenard M. Parkins (NY Bar # 4579124) John D. Penn (NY Bar # 4847208 and admitted pro hac vice) Trevor Hoffmann (NY Bar # 4067229) Mark Elmore (admitted pro hac vice) Attorneys for Midland Loan Services, Inc. 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

MOTION OF LENARD M. PARKINS FOR ADMISSION PRO HAC VICE OF PHILLIP M. BRIDWELL Lenard M. Parkins (Movant), a member in good standing of the Bar of the State of New York, an attorney admitted to practice before the United States District Court for the Southern District of New York, and associated with Haynes and Boone, LLP (Haynes and Boone), hereby moves (the Motion) this Court for an order admitting Phillip M. Bridwell (Mr. Bridwell) pro hac vice to represent Midland Loan Services, Inc., in the above-captioned cases (the Cases) pursuant to Rule 2090-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York (the Local Rules). In support of this Motion, Movant relies upon the respective certification of Mr. Bridwell which is annexed as Exhibit A hereto and respectfully represents as follows: 1. Phillip M. Bridwell (phillip.bridwell@haynesboone.com) is an associate at

Haynes and Boone. Mr. Bridwell is a member in good standing of the Bar of the State of Texas
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and is admitted to practice before all state courts in Texas. Mr. Bridwell is admitted to practice before the United States Court of Appeals for the Eleventh Circuit and the United States District Courts for the Northern and Eastern Districts of Texas. There are no disciplinary proceedings or criminal proceedings pending against Mr. Bridwell in any jurisdiction and there has been no disclosure of any pending grievances against him. The Certification of Mr. Bridwell is annexed hereto as Exhibit A in support of the Motion. 2. Movant requests that this Court approve the Motion so that the Mr. Bridwell may

file pleadings, appear and be heard at hearings, and otherwise represent Midland Loan Services, Inc. in these Cases. 3. Pursuant to Rule 9013-a(b) of the Local Rules, because there are no novel issues

of law presented herein, Movant respectfully requests that the Court waive the requirement that a memorandum of law be filed in support of this Motion. WHEREFORE, Movant respectfully requests that the Court: (a) enter an order admitting Mr. Bridwell pro hac vice to represent Midland Loan

Services, Inc. in these Cases; and

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(b)

grant such other and further relief as is just and proper.

Dated: August 31, 2010 HAYNES AND BOONE, LLP

/s/ Lenard M. Parkins Lenard M. Parkins (NY Bar # 4579124) John D. Penn (NY Bar # 4847208 and admitted pro hac vice) Trevor Hoffmann (NY Bar # 4067229) Mark Elmore (admitted pro hac vice) 1221 Avenue of the Americas, 26th Floor New York, NY 10020 Telephone: (212) 659-7300 Facsimile: (212) 918-8989

ATTORNEYS FOR MIDLAND LOAN SERVICES, INC.

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Exhibit A

HAYNES AND BOONE, LLP 1221 Avenue of the Americas, 26th Floor New York, New York 10020 Telephone: (212) 659-7300 Facsimile: (212) 884-8211 Lenard M. Parkins (NY Bar # 4579124) John D. Penn (NY Bar # 4847208 and admitted pro hac vice) Trevor Hoffmann (NY Bar # 4067229) Mark Elmore (admitted pro hac vice) Attorneys for Midland Loan Services, Inc. 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

CERTIFICATION OF PHILLIP M. BRIDWELL I, Phillip M. Bridwell, in support of the Motion of Lenard M. Parkins for Admission Pro Hac Vice of Phillip M. Bridwell, do hereby certify under penalty of perjury as follows: 1. 2. I am eligible for admission pro hac vice to this Court. I am an associate at the law firm of Haynes and Boone, LLP and maintain an

office for the practice of law at 2323 Victory Avenue, Suite 700, Dallas, Texas 75219. 3. I am a member in good standing of the Bar of the State of Texas (TX Bar

#24068004), and have been admitted to practice before the United States Court of Appeals for the Eleventh Circuit and the United States District Courts for the Northern and Eastern Districts of Texas. There are no disciplinary proceedings or criminal proceedings pending against me and there have been no disclosures of any pending formal grievances against me.

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4.

I submit to the disciplinary jurisdiction of this Court for any alleged misconduct

which may occur in the course, or in the preparation, of this Chapter 11 case, pursuant to Rule 2090-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York (the Local Rules). 5. I have access to, or have acquired, a copy of the Local Rules, am generally

familiar with such Rules, and will comply with such Rules. I certify under penalty of perjury that the foregoing is true and correct. Executed on August 31, 2010. HAYNES AND BOONE, LLP

/s/ Phillip M. Bridwell Phillip M. Bridwell (TX Bar #24068004) 2323 Victory Avenue Suite 700 Dallas, Texas 75219 Telephone: (214) 651-5000 Facsimile: (214) 651-5940

ATTORNEYS FOR MIDLAND LOAN SERVICES, INC.

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HAYNES AND BOONE, LLP 1221 Avenue of the Americas, 26th Floor New York, New York 10020 Telephone: (212) 659-7300 Facsimile: (212) 884-8211 Lenard M. Parkins (NY Bar # 4579124) John D. Penn (NY Bar # 4847208 and admitted pro hac vice) Trevor Hoffmann (NY Bar # 4067229) Mark Elmore (admitted pro hac vice) Attorneys for Midland Loan Services, Inc. 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 GRANTING MOTION FOR ADMISSION PRO HAC VICE OF PHILLIP M. BRIDWELL Upon the Motion (the Motion) of Lenard M. Parkins seeking the admission pro hac vice of Phillip M. Bridwell to represent Midland Loan Services, Inc. in the above-mentioned case; and upon consideration of the Motion and, the Certification of Phillip M. Bridwell; and the Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; and after due deliberation and sufficient cause appearing therefore, it is ORDERED that Phillip M. Bridwell is admitted pro hac vice to represent Midland Loan Services, Inc. in the above-captioned cases and he may appear in these cases and any related proceedings pro hac vice; and it is further

N-89711_1.DOC

ORDERED that the requirements of service and filing of a separate memorandum of law under Rule 9013-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York is hereby waived. Dated: August ____, 2010 New York, New York ____________________________________ UNITED STATES BANKRUPTCY JUDGE

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