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James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to AP Services, LLC, in its capacity as Trustee UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al.,1 Debtors. ) ) ) ) ) ) ) Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

NOTICE OF FILING OF STIPULATION AND AGREED ORDER RESOLVING DEBTORS OBJECTIONS TO GUARANTY CLAIMS ASSERTED BY TRIMONT REAL ESTATE ADVISORS, INC. AND LEHMAN ALI, INC. AGAINST GRAND PRIX HOLDINGS LLC 1 PLEASE TAKE NOTICE that the Trustee2 for the Liquidating Trust hereby files the Stipulation and Agreed Order Resolving Debtors Objection to Guaranty Claims Asserted by

The list of Debtors in these Chapter 11 Cases along with the last four digits of each Debtors federal tax identification number can be found by visiting the Debtors restructuring website at www.omnimgt.com/innkeepers or 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. The location of the Debtors corporate headquarters and the service address for their affiliates is: c/o Innkeepers USA, 340 Royal Poinciana Way, Suite 306, Palm Beach, Florida 33480.

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Trimont Real Estate Advisors, Inc. and Lehman ALI, Inc. Against Grand Prix Holdings LLC (the Stipulation and Agreed Order). The Stipulation and Agreed Order resolves the

Debtors Objection to Guaranty Claims Asserted by Trimont Real Estate Advisors, Inc. Against Grand Prix Holdings LLC [Docket No. 1865] and the Debtors Objection to Guaranty Claim Asserted by Lehman ALI, Inc. Against Grand Prix Holdings LLC [Docket No. 1866]. PLEASE TAKE FURTHER NOTICE that the Debtors will present the Stipulation and Agreed Order to the Bankruptcy Court for approval at the omnibus hearing scheduled for March 28, 2012, at 10:00 a.m. prevailing Eastern Time. PLEASE TAKE FURTHER NOTICE that copies of the documents referenced herein may be obtained free of charge by visiting the Debtors restructuring website at www.omnimgt.com/innkeepers or 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. You may also obtain copies of any pleadings by visiting the Courts website at http://www.nysb.uscourts.gov in accordance with the procedures and fees set forth therein.

Capitalized terms used herein and not otherwise defined herein shall have the meanings set forth in the Debtors Plans of Reorganization Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 1445].

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New York, New York Dated: March 26, 2012

/s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the AP Services, LLC, in its capacity as Trustee

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