BRYAN CAVE LLP Lawrence P.

Gottesman (LG-7061) Michelle McMahon (MM-8130) 1290 Avenue of the Americas New York, New York 10104 (212) 541-2000 and DUANE MORRIS LLP Phillip K. Wang, Esq. (admitted pro hac vice) One Market Plaza, Spear Tower, Suite 2200 San Francisco, CA 94105-1127 (415) 957-3185

Objection Deadline: Aug. 25, 2010 Hearing Date: Aug. 25, 2010 at 11:00 a.m.

Attorneys for 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. Bank National Association, as Trustee for the registered holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re: INNKEEPERS USA TRUST, et al., Debtors. : : (Jointly Administered) : x RESPONSE 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. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE REGISTERED HOLDERS OF ML-CFC COMMERCIAL MORTGAGE TRUST 2006-4, COMMERCIAL MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-4 TO THE MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF INNKEEPERS USA TRUST, ET AL. FOR AN ORDER PERMITTING THE COMMITTEE TO CONDUCT RULE 2004 DISCOVERY OF INNKEEPERS USA TRUST ET AL. AND OTHER PARTIES 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 Chapter 11 Case No.: 10-13800 (SCC)

2007-C1 and U.S. Bank National Association, as Trustee for the registered holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 (jointly, the Property Level Lenders), by their undersigned counsel, as and for their Response to the Motion of the Official Committee of Unsecured Creditors of Innkeepers USA Trust, et. al. for an Order Permitting the Committee to Conduct Rule 2004 Discovery of Innkeepers USA Trust, et. al. and Other Parties (the Motion), respectfully represent as follows:1 1. On July 19, 2010 (the Petition Date), the Debtors filed voluntary petitions for

relief under chapter 11 of the Bankruptcy Code commencing these bankruptcy cases. 2. The Debtors are debtors-in-possession and continue to operate their businesses

pursuant to 11 U.S.C. 1107 and 1108. 3. July 28, 2010. 4. The Property Level Lenders are commercial mortgage backed securitization trusts An official committee of unsecured creditors (the Committee) was appointed on

and hold mortgage loans (collectively, the Property Level Loans) secured by first-priority, perfected mortgages, liens and security interests on and in each of the hotel properties commonly know as Residence Inn San Diego, Residence Inn Garden Grove, Double Tree Guest Suites Washington D.C., Residence Inn Tysons Corner, and Homewood Suites San Antonio (collectively, the Hotel Properties) and related personal property (including all cash generated thereby), owned or leased by certain of the Debtors (the Property Level Debtors) arising from various secured loan transactions entered into prior to the Petition Date, all as more particularly described in the applicable mortgages, notes, agreements and all other documents executed or
Unless otherwise defined herein, all capitalized terms used herein shall have the same meanings ascribed to such terms in the Motion.
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delivered in connection with each Property Level Loan (collectively, the Loan Documents). As of the Petition Date, the aggregate outstanding unpaid principal balance of the Property Level Loans was in the approximate amount of $160 million.2 5. The Property Level Lenders do not object to reasonable discovery pursuant to

Rule 2004 of the Federal Rules of Bankruptcy Procedure. The Property Level Lenders will endeavor to work with the Committee to appropriately tailor the scope, nature and timing of such discovery, taking into account, among other things, that the Property Level Loans held by the Property Level Lenders were originated prior to and were not part of the 2007 Transaction and the fact that relevant documents with respect to such matter can be most efficiently obtained from the entities that were parties thereto. 6. The Property Level Lenders reserve all rights with respect to the Rule 2004

Motion, including the right to object to any subpoena served on the Property Level Lenders by the Committee. Dated: August 25, 2010 New York, New York

BRYAN CAVE LLP

/s/ Lawrence P. Gottesman Lawrence P. Gottesman (LG-7061) Michelle McMahon (MM-8130) 1290 Avenue of the Americas New York, New York 10104 Tel: 212-541-2000; Fax: 212-541-4630
lawrence.gottesman@bryancave.com michelle.mcmahon@bryancave.com

and DUANE MORRIS LLP

This amount does not include accrued and unpaid yield maintenance premiums, interest at the base and default rates, late charges and fees, attorneys fees and expenses and various other amounts in addition to the outstanding principal balances that are or may be due under the Loan Documents.
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Phillip K. Wang, Esq. (admitted pro hac vice) San Francisco, CA 94105-1127 Tel: (415) 957.3185; Fax: (415) 358.4725 pwang@duanemorris.com Attorneys for 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. Bank National Association, as Trustee for the registered holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4

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