Hearing Date: November 10, 2010 at 10:00 a.m. Objection Date: October 27, 2010 at 5:00 p.m.

DECHERT LLP 1095 Avenue of the Americas New York, New York 10036-6797 Telephone: (212) 698-3500 Facsimile: (212) 698-3599 Michael J. Sage Brian E. Greer Andrew L. Buck Attorneys for Lehman ALI Inc. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------ X : In re: : Chapter 11 : INNKEEPERS USA TRUST, et al. : Case No. 10-13800 : Debtors. : Jointly Administered : ------------------------------------------------------------ X STATEMENT OF LEHMAN ALI INC. WITH RESPECT TO MOTIONS TO TERMINATE EXCLUSIVITY Lehman ALI Inc. (Lehman)1 submits this statement with respect to (i) Midland Loan Services, Inc.s Motion to Terminate Exclusivity [Docket No. 348] and (ii) the Motion of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp. Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S.
1

Twenty of the Debtors (the Floating Rate Debtors) in the above-captioned cases are borrowers under that certain Loan Agreement, dated as of June 29, 2007, in the original principal amount of $250,000,000.00, between and among the Floating Rate Debtors, as borrowers, and Lehman, as lender (as amended, the Floating Rate Loan Agreement). The Floating Rate Debtors obligations under the Floating Rate Loan Agreement are secured by twenty separate mortgages (each, a Floating Rate Mortgage) that each grant Lehman (i) a first lien mortgage on the applicable hotel property, (ii) a lien on all cash, accounts, and proceeds of the applicable borrower, and (iii) an absolute assignment of rents of the applicable hotel property. The Floating Rate Debtors are: (1) KPA/GP Valencia LLC; (2) Grand Prix West Palm Beach LLC; (3) KPA/GP Ft. Walton Beach LLC; (4) Grand Prix Ft. Wayne LLC; (5) Grand Prix Indianapolis LLC; (6) KPA/GP Louisville (HI) LLC; (7) Grand Prix Bulfinch LLC; (8) Grand Prix Woburn LLC; (9) Grand Prix Rockville LLC; (10) Grand Prix East Lansing LLC; (11) Grand Prix Grand Rapids LLC; (12) Grand Prix Troy (Central) LLC; (13) Grand Prix Troy (SE) LLC; (14) Grand Prix Atlantic City LLC; (15) Grand Prix Montvale LLC; (16) Grand Prix Morristown LLC; (17) Grand Prix Albany LLC; (18) Grand Prix Addison (SS) LLC; (19) Grand Prix Harrisburg LLC; and (20) Grand Prix Ontario LLC.

Bank National Association, as Successor to LaSalle Bank N.A., formerly known as LaSalle National Bank, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 to Terminate Exclusivity and Joinder to Midland Loan Services, Inc.s Motion to Terminate Exclusivity [Docket No. 437] (collectively, the Exclusivity Motions)2 and respectfully states as follows: 1. Section 1121(c)(2) of the Bankruptcy Code grants the Debtors the exclusive right

to file a plan of reorganization until 120 days after the commencement of these chapter 11 cases. 11 U.S.C. 1121(b). The Debtors exclusive period expires on November 16, 2010, unless the Court extends exclusivity for cause. 2. 3. At this time, Lehman takes no position with respect to the Exclusivity Motions. If the Court determines to grant the relief requested in the Exclusivity Motions,

Lehman submits that the Court should terminate exclusivity for all Debtors and permit all parties in interest, including Lehman, to file and solicit a plan or plans as they deem appropriate. See 11 U.S.C. 1121 (c)(2) and (d); In re Express One Int'l, 194 B.R. 98, 100 (Bankr. E.D. Tex. 1996) (upon termination of exclusivity, any party in interest may file a plan of reorganization).

Capitalized terms used but not defined herein shall have the meanings ascribed thereto in the Exclusivity Motions.

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Lehman reserves its right to supplement this response at the hearing on the

Exclusivity Motions and to object to any extension of exclusivity sought by the Debtors. Dated: New York, New York October 27, 2010 DECHERT LLP

By: /s/ Michael J. Sage Michael J. Sage Brian E. Greer Andrew L. Buck 1095 Avenue of the Americas New York, New York 10036 Telephone: (212) 698-3500 Facsimile: (212) 698-3599