Hearing Date: September 30, 2010 at 10:00 a.m. (EDT) Objection Deadline: September 23, 2010 at 5:00 p.m.

(EDT)

HAYNES AND BOONE, LLP 1221 Avenue of the Americas, 26th Floor New York, NY 10020 Telephone: (212) 659-7300 Facsimile: (212) 918-8989 Lenard M. Parkins (NY Bar #4579124) John D. Penn (NY Bar # 4847208, admitted pro hac vice) Mark Elmore (admitted pro hac vice) Attorneys for Midland Loan Services, Inc. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al., Debtors. ) ) ) ) ) ) ) Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

NOTICE OF HEARING ON MIDLAND LOAN SERVICES, INC.'S MOTION TO TERMINATE EXCLUSIVITY PLEASE TAKE NOTICE that a hearing to consider the relief requested in the Motion of Midland Loan Services, Inc. (Midland), To Terminate Exclusivity, dated August 30, 2010, shall be held before the Honorable Shelley C. Chapman of the United States Bankruptcy Court for the Southern District of New York (the Bankruptcy Court) on September 30, 2010, at 10:00 a.m. (EDT), or as soon thereafter as counsel may be heard. PLEASE TAKE FURTHER NOTICE THAT responses or objections, if any, to the Motion and the relief requested therein shall be made in writing, shall state with particularity the grounds therefor, shall conform to the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the Southern District of New York, and shall be filed with the Bankruptcy Court electronically in accordance with General Order M-242 (N.B. General Order M-242 and

the

Users

Manual

for

the

Electronic

Case

Filing

System

can

be

found

at

www.nysb.uscourts.gov, the official website for the United States Bankruptcy Court for the Southern District of New York) by registered users of the Bankruptcy Courts electronic filing system, and, by all other parties in interest, on a 3.5 inch disk, preferably in Printable Document Format (PDF), WordPerfect or any other Windows-based word processing format (with a hard copy delivered directly to Chambers) and served in accordance with General Order M-242 or otherwise so as to be actually received no later than 5:00 p.m. (EDT) on September 23, 2010 by: (i) Haynes and Boone, LLP, Attorneys for Midland, 1221 Avenue of the Americas, 26th Floor, New York, New York, 10020 (Attn: Lenard M. Parkins, Esq.); (ii) Kirkland & Ellis, LLP, Attorneys for the Debtors, 601 Lexington Avenue, New York, New York 10022 (Attn: Jennifer Marines and Paul M. Basta, Esq.); (iii) the Office of the United States Trustee, 33 Whitehall Street, New York, New York 10004 (Attn: Paul Schwartzberg, Esq.); and (iv) Morrison & Foerster LLP, Attorneys for the Official Committee of Unsecured Creditors, 1290 Avenue of the Americas, New York, New York 10104 (Attn: Lorenzo Marinuzzi, Esq.).

N-90323_1.DOC

PLEASE TAKE FURTHER NOTICE that if no objections are filed and served as prescribed herein, the relief requested by Midland may be granted without further hearing or notice. Dated: New York, New York September 8, 2010 HAYNES AND BOONE, LLP

/s/ Lenard M. Parkins Lenard M. Parkins (NY Bar #4579124) Mark Elmore (admitted pro hac vice) 1221 Avenue of the Americas, 26th Floor New York, NY 10020-1007 Telephone No.: (212) 659-7300 Facsimile No.: (212) 884-8211 - and John D. Penn, Esq. (NY Bar # 4847208, admitted pro hac) Haynes and Boone, LLP 201 Main Street, Suite 2200 Fort Worth, Texas 76102 Telephone No.: (817) 347-6610 Facsimile No.: (817) 348-2300

ATTORNEYS FOR MIDLAND LOAN SERVICES, INC.

N-90323_1.DOC