Objection Deadline: March 21, 2011 at 4:00 p.m.

(ET)

James H.M. Sprayregen, P.C. Paul M. Basta KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al.,1 Debtors. ) ) ) ) ) ) ) Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

NOTICE OF FEE STATEMENT OF MOELIS & COMPANY LLC FOR THE PERIOD FROM DECEMBER 1, 2010 THROUGH DECEMBER 31, 20101 PLEASE TAKE NOTICE that, on March 1, 2011, Kirkland & Ellis LLP (K&E) filed the above-referenced application (the Application) on behalf of Moelis & Company LLC

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 by 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. 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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(Moelis).2 The Application is filed with the Court at Docket No. 959 and may be obtained (a) from the Debtors Notice and Claims Agent by: (i) visiting

http://www.omnimgt.com/innkeepers; (ii) writing to Innkeepers USA Trust c/o Omni Management Group, LLC, 16161 Ventura Boulevard, Suite C, PMB 606, Encino, California, 91436; or (iii) calling (866) 989-6147, or (b) for a fee via PACER at

http://www.nysb.uscourts.gov. A copy of the Application can also be obtained upon written request to K&E. PLEASE TAKE FURTHER NOTICE that any responses or objections to the Application, which may only be filed by a Notice Party (as defined in the Interim Compensation Order [Docket No. 189]): must be in writing; shall conform to the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), all General Orders and Local Rules for the United States Bankruptcy Court for the Southern District of New York, and the Interim Compensation Order; shall be filed with the Bankruptcy Court electronically by registered users of the Bankruptcy Courts case filing system (the Users Manual for the Electronic Case Filing System can be found at www.nysb.uscourts.gov, the official website for the Bankruptcy Court); and shall be served so as to be actually received no later than March 21, 2011 at 4:00 p.m. prevailing Eastern Time (the Objection Deadline) by: (a) the Debtors; (b) the Office of the United States Trustee for the Southern District of New York; (c) counsel to the Official Committee of Unsecured Creditors; (d) counsel to Midland Loan Services, Inc.; (e) counsel to Certain Prepetition Lenders; and (f) Moelis (each as defined in the Interim Compensation Order).

Capitalized terms used but not defined herein have the meanings ascribed to them in the Application.

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PLEASE TAKE FURTHER NOTICE that if an objection to the Application is timely filed, objecting parties may be required to attend a hearing, and failure to appear may result in the relief being granted or denied upon default. PLEASE TAKE FURTHER NOTICE that payment of the amounts requested in the Application shall be as set forth in the Interim Compensation Order.

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New York, New York Dated: March 1, 2011

/s/ Paul M. Basta James H.M. Sprayregen, P.C. Paul M. Basta KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession

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