Objection Deadline: Aug. 23, 2010 Hearing Date: Sept. 1, 2010 at 8:30 a.m. Lee S. Attanasio John G.

Hutchinson John J. Lavelle SIDLEY AUSTIN LLP 787 Seventh Avenue New York, NY 10019 (212) 839-5300 Attorneys for Appaloosa Investment L.P. I UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------x In re : : : Innkeepers USA Trust, et al., : Debtors. : ------------------------------------------------------x

Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

NOTICE OF UNSEALING OF THE OBJECTION OF APPALOOSA INVESTMENT L.P. I, TO: (I) DEBTORS MOTION FOR THE ENTRY OF INTERIM AND FINAL ORDERS (A) AUTHORIZING THE DEBTORS TO (I) USE THE ADEQUATE PROTECTION PARTIES CASH COLLATERAL AND (II) PROVIDE ADEQUATE PROTECTION TO THE ADEQUATE PROTECTION PARTIES PURSUANT TO 11 U.S.C. SEC. 361, 362, AND 363, (B) TO THE EXTENT APPROVED IN THE FINAL ORDER, GRANTING SENIOR SECURED, PRIMING LIENS ON CERTAIN POSTPETITION INTERCOMPANY CLAIMS, AND (D) SCHEDULING A FINAL HEARING PURSUANT TO BANKRUPTCY RULE 4001(B); AND (II) DEBTORS MOTION FOR AN ORDER (A) AUTHORIZING THE DEBTORS TO ASSUME THE PLAN SUPPORT AGREEMENT AND (B) GRANTING RELATED RELIEF

Appaloosa Investment L.P. I (Appaloosa), a party in interest in these cases, by and through their counsel, hereby state that its Objection (the Objection) to the following motions: (i) Debtors Motion for the Entry of Interim and Final Orders (A) Authorizing the Debtors to (I) Use the Adequate Protection Parties Cash Collateral and (II) Provide Adequate Protection to the Adequate Protection Parties Pursuant to 11 U.S.C. Sec. 361, 362, and 363, (B) to the Extent Approved in the Final Order, Granting Senior Secured, Priming Liens on Certain

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Postpetition Intercompany Claims, (C) to the Extent Approved in the Final Order, Granting Administrative Priority Status to Certain Postpetition Intercompany Claims, and (D) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(B) [Docket No. 13] (the Cash Collateral Motion); and (ii) Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 15] (the PSA Motion and together with the Cash Collateral Motion, the Motions), filed by the above captioned debtors and debtors-in-possession (collectively, the Debtors), is now unsealed. Such Objection has been filed with the United States Bankruptcy Court for the Southern District of New York (the Court). The Objection and all replies and supporting exhibits (collectively, the Filings) may be obtained, free of charge, by either 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. A copy of this Notice and the Objection has also been served in accordance with the Case Management Order (Docket No. 68) entered in this case. The Filings may also be obtained by visiting the Courts website at http://www.nysb.uscourts.gov in accordance with the procedures and fees set forth therein. Dated: New York, New York September 1, 2010 Respectfully submitted, SIDLEY AUSTIN LLP

By: /s/ Lee S. Attanasio Lee S. Attanasio John G. Hutchinson John J. Lavelle 787 Seventh Avenue New York, New York 10019 Telephone: (212) 839-5300

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Facsimile: (212) 839-5599 lattanasio@sidley.com jhutchinson@sidley.com jlavelle@sidley.com Attorneys for Appaloosa Investment L.P. I

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