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 Nicole B. Herther-Spiro 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 RESERVATION OF RIGHTS OF LEHMAN ALI INC. WITH RESPECT TO THE DEBTORS DISLCOSURE STATEMENT AND PLANS OF REORGANIZATION Lehman ALI Inc. (Lehman) submits this reservation of rights (this Reservation of Rights) with respect to the Debtors Motion for Entry of an Order Approving (a) Adequacy of the Disclosure Statement; (b) Certain Dates Related to Confirmation of the Plan; (c) Certain Voting Procedures and the Form of Certain Documents to be Distributed in Connection with Solicitation of the Plan; and (d) Proposed Voting and General Tabulation Procedures [Dkt. No. 1095] (the Motion), and respectfully states as follows:1 As the Debtors have acknowledged, the Plans of Reorganization Pursuant to Chapter 11 of the Bankruptcy Code [Dkt. No. 1094] (the Plans) and the related Disclosure Statement [Dkt. No. 1093] (the Disclosure Statement) filed by the Debtors were not acceptable in all respects
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Capitalized terms not herein defined shall have the meanings assigned in the Motion.

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to Lehman in accordance with the Commitment Letter. See Notice of Filing Debtors Disclosure Statement and Plans [Dkt. No. 1096]. Moreover, the Plans and Disclosure Statement have not yet been revised to reflect the outcome of the auction for the Fixed/Floating Hotels and other assets that occurred on May 2, 2011, and the Debtors have yet to circulate revised drafts of such documents. Accordingly, Lehman hereby reserves all rights with respect to the Motion, Plan, and Disclosure Statement, including its rights to file a written objection or raise any other objection at the hearing on the Motion. Dated: New York, New York May 6, 2011 Respectfully Submitted, DECHERT LLP

By:/s/ Michael J. Sage Michael J. Sage Brian E. Greer Nicole B. Herther-Spiro 1095 Avenue of the Americas New York, New York 10036-6797 Telephone: (212) 698-3500 Facsimile: (212) 698-3599 michael.sage@dechert.com brian.greer@dechert.com nicole.hertherspiro@dechert.com Attorneys for Lehman ALI Inc.