UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al., Debtors.

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

INNKEEPERS USA TRUST, et al., Plaintiffs, v. CERBERUS SERIES FOUR HOLDINGS, LLC, CHATHAM LODGING TRUST, INK ACQUISITION LLC, and INK ACQUISITION II LLC, Defendants.

Adversary Proceeding Case No. 11-02557 (SCC)

ORDER GRANTING JOINT MOTION FOR AUTHORITY TO FILE UNDER SEAL PRE-TRIAL AND POST-TRIAL BRIEFING AND EXHIBITS THERETO 2 Upon consideration of the Parties joint motion (this Motion) for the entry of an order (a) authorizing the Parties, or any other entity filing a pretrial or opposition brief, to file under seal all pretrial and opposition briefs, supporting papers and exhibits thereto, that contain AEO Material, Highly Confidential Material or Confidential Material (as defined in the Amended Stipulated Protective Order [Docket No. 34]), and (b) directing that unredacted versions of the

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 on 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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documents filed under seal shall remain under seal and not be made available to anyone without the consent of the Parties or further order of the Court; and it appearing that pursuant to Fed. R. Bankr. P. 9018, no notice of the relief requested in the Motion need be provided; and the Court having determined that the legal and factual bases set forth in the Motion establish just cause for the relief granted herein; and upon all of the proceedings had before the Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. 2. The Motion is granted to the extent provided herein. Pursuant to 11 U.S.C. 107(b) and Fed. R. Bankr. P. 9018, the Parties are

authorized to file under seal all pre-trial and post-trial briefing, supporting papers and exhibits thereto, including reply briefs, that contain AEO Material, Highly Confidential Material or Confidential Material, and the sealed documents shall not be made available to any party without the consent of the Parties or by further order of the Court. 3. The sealed documents (and any information derived from the sealed documents)

shall remain confidential, be filed under seal, and shall be served on and made available only to (a) parties that have signed on to the Amended Stipulated Protective Order, (b) those parties listed in paragraphs 10-12 in the Amended Stipulated Protective Order; and (c) such other parties as ordered by this Court or as agreed to in writing by the Parties. 4. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 5. All time periods set forth in this Order shall be calculated in accordance with

Bankruptcy Rule 9006(a). 6. The Court retains jurisdiction to enforce this Order and the confidentiality of all

documents filed under seal pursuant to this Order and the sensitive information contained

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therein, including the authority to impose sanctions on any person or entity that violates this Order.

Dated: October 3, 2011 New York, New York /s/ Shelley C. Chapman Honorable Shelley C. Chapman United States Bankruptcy Judge

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