Hearing Date: October 6, 2011, at 10:00 a.m.. Objection Deadline: September 28, 2011, at 4:00 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 Nicole B. Herther-Spiro Attorneys for Lehman ALI Inc. and SASCO 2008-C2, LLC 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. AND SASCO 2008-C2, LLC WITH RESPECT TO THE THIRD INTERIM APPLICATION OF JEFFERIES & COMPANY, INC., FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF INNKEEPERS USA TRUST, ET AL., FOR INTERIM ALLOWANCE OF COMPENSATION AND FOR THE REIMBURSEMENT OF EXPENSES FOR SERVICES RENDERED DURING THE PERIOD FROM APRIL 1, 2011 THROUGH JULY 31, 2011 Lehman ALI Inc. (Lehman ALI) and SASCO 2008-C2, LLC (SASCO, together with Lehman ALI, Lehman)1 submit this reservation of rights with respect to the Third Interim Application of Jefferies & Company, Inc., Financial Advisor to the Official Committee of Unsecured Creditors of Innkeepers USA Trust, et al., for Interim Allowance of Compensation

The loan agreements and related agreements giving rise to Lehmans claims against certain of the debtors and debtors in possession in the above-captioned cases are described in prior pleadings filed by Lehman.

and for the Reimbursement of Expenses for Services Rendered During the Period from April 1, 2011 through July 31, 2011 [Dkt. No. 2092] (the Jefferies Fee Application), and respectfully state as follows: Lehman hereby reserves all rights with respect to the Jefferies Fee Application. In doing so, Lehman specifically reserves the right to assert objections to fees and expenses incurred by Jefferies & Company, Inc. in connection with these chapter 11 cases at the final hearing to approve such fees and expenses.

Dated: New York, New York September 28, 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. and SASCO 2008-C2, LLC