James H.M. Sprayregen, P.C. Paul M. Basta Jennifer L.

Marines 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. (admitted pro hac vice) 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

PROPOSED AGENDA FOR AUGUST 31, 2010 AND SEPTEMBER 1, 2010 HEARINGS1

The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtors federal tax identification number, are: GP AC Sublessee LLC (5992); Grand Prix Addison (RI) LLC (3740); Grand Prix Addison (SS) LLC (3656); Grand Prix Albany LLC (3654); Grand Prix Altamonte LLC (3653); Grand Prix Anaheim Orange Lessee LLC (5925); Grand Prix Arlington LLC (3651); Grand Prix Atlanta (Peachtree Corners) LLC (3650); Grand Prix Atlanta LLC (3649); Grand Prix Atlantic City LLC (3648); Grand Prix Bellevue LLC (3645); Grand Prix Belmont LLC (3643); Grand Prix Binghamton LLC (3642); Grand Prix Bothell LLC (3641); Grand Prix Bulfinch LLC (3639); Grand Prix Campbell / San Jose LLC (3638); Grand Prix Cherry Hill LLC (3634); Grand Prix Chicago LLC (3633); Grand Prix Columbia LLC (3631); Grand Prix Denver LLC (3630); Grand Prix East Lansing LLC (3741); Grand Prix El Segundo LLC (3707); Grand Prix Englewood / Denver South LLC (3701); Grand Prix Fixed Lessee LLC (9979); Grand Prix Floating Lessee LLC (4290); Grand Prix Fremont LLC (3703); Grand Prix Ft. Lauderdale LLC (3705); Grand Prix Ft. Wayne LLC (3704); Grand Prix Gaithersburg LLC (3709); Grand Prix General Lessee LLC (9182); Grand Prix Germantown LLC (3711); Grand Prix Grand (continued on next page)

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Time and Date of Hearings:

August 31, 2010 at 1:30 p.m. (prevailing Eastern Time) August 31, 2010 at 2:00 p.m. (prevailing Eastern Time) September 1, 2010 at 8:30 a.m. (prevailing Eastern Time) Hon. Shelley C. Chapman United States Bankruptcy Court for the Southern District of New York Courtroom No. 610 One Bowling Green Alexander Hamilton Custom House New York, New York 10004 A copy of each pleading can be viewed on the Courts website at ecf.nysb.uscourts.gov and at the website of the Debtors proposed notice and claims agent, Omni Management Group, LLC (Omni), at www.omnimgt.com/innkeepers. Further information may be obtained by calling Omni at (866) 989-6147.

Location of Hearing:

Copies of Motions:

Rapids LLC (3713); Grand Prix Harrisburg LLC (3716); Grand Prix Holdings LLC (9317); Grand Prix Horsham LLC (3728); Grand Prix IHM, Inc. (7254); Grand Prix Indianapolis LLC (3719); Grand Prix Islandia LLC (3720); Grand Prix Las Colinas LLC (3722); Grand Prix Lexington LLC (3725); Grand Prix Livonia LLC (3730); Grand Prix Lombard LLC (3696); Grand Prix Louisville (RI) LLC (3700); Grand Prix Lynnwood LLC (3702); Grand Prix Mezz Borrower Fixed, LLC (0252); Grand Prix Mezz Borrower Floating, LLC (5924); Grand Prix Mezz Borrower Floating 2, LLC (9972); Grand Prix Mezz Borrower Term LLC (4285); Grand Prix Montvale LLC (3706); Grand Prix Morristown LLC (3738); Grand Prix Mountain View LLC (3737); Grand Prix Mt. Laurel LLC (3735); Grand Prix Naples LLC (3734); Grand Prix Ontario Lessee LLC (9976); Grand Prix Ontario LLC (3733); Grand Prix Portland LLC (3732); Grand Prix Richmond (Northwest) LLC (3731); Grand Prix Richmond LLC (3729); Grand Prix RIGG Lessee LLC (4960); Grand Prix RIMV Lessee LLC (4287); Grand Prix Rockville LLC (2496); Grand Prix Saddle River LLC (3726); Grand Prix San Jose LLC (3724); Grand Prix San Mateo LLC (3723); Grand Prix Schaumburg LLC (3721); Grand Prix Shelton LLC (3718); Grand Prix Sili I LLC (3714); Grand Prix Sili II LLC (3712); Grand Prix Term Lessee LLC (9180); Grand Prix Troy (Central) LLC (9061); Grand Prix Troy (SE) LLC (9062); Grand Prix Tukwila LLC (9063); Grand Prix West Palm Beach LLC (9065); Grand Prix Westchester LLC (3694); Grand Prix Willow Grove LLC (3697); Grand Prix Windsor LLC (3698); Grand Prix Woburn LLC (3699); Innkeepers Financial Corporation (0715); Innkeepers USA Limited Partnership (3956); Innkeepers USA Trust (3554); KPA HI Ontario LLC (6939); KPA HS Anaheim, LLC (0302); KPA Leaseco Holding Inc. (2887); KPA Leaseco, Inc. (7426); KPA RIGG, LLC (6706); KPA RIMV, LLC (6804); KPA San Antonio, LLC (1251); KPA Tysons Corner RI, LLC (1327); KPA Washington DC, LLC (1164); KPA/GP Ft. Walton LLC (3743); KPA/GP Louisville (HI) LLC (3744); KPA/GP Valencia LLC (9816). 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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I.

Hearing Scheduled for August 31, 2010 at 1:30 p.m. (prevailing Eastern Time)

PLEASE TAKE NOTICE THAT THE MATTERS SCHEDULED FOR 1:30 P.M. (PREVAILING EASTERN TIME) ARE CONFIDENTIAL AND WILL NOT BE OPEN TO THE PUBLIC A. Marriott Related Matters 1. Settlement Agreement Amended Notice of Presentment of Stipulation Between Innkeepers USA Trust and Marriott International, Inc. and Order Approving Settlement of Marriotts Motion for Limited Modification of the Automatic Stay and Debtors Motion to Assume the Troy Central Franchise Agreement [Docket No. 325]

Responses Received: a. Midland Loan Services, Inc.s Limited Objection to Stipulation Between Innkeepers USA Trust and Marriott International, Inc. [Docket No. 333] Declaration of John D. Penn in Support of Midland Loan Services, Inc.s Limited Objection to Stipulation Between Innkeepers USA Trust and Marriott International, Inc. [Docket No. 344] b. Joinder of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4 to Midland Loan Services, Inc.s Limited Objection to Stipulation Between Innkeepers USA Trust and Marriott International, Inc. [Docket No. 335]

Replies Received: None Related Documents: c. Marriott International, Inc.s Motion for Limited Modification of the Automatic Stay to Complete De-Identification of a Single Hotel in Accordance with the Prepetition Termination of the Franchise Agreement Which is Effective on August 30, 2010 [Docket No. 131] Declaration of Karl Grover in Support of Marriott International, Inc.s Motion for Limited Modification of the Automatic Stay to Complete De-Identification of a Single Hotel in Accordance with 3
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the Prepetition Termination of the Franchise Agreement Which is Effective on August 30, 2010 [Docket No. 131] [Docket No. 132] d. e. Debtors Motion for Entry of an Order Authorizing the Debtors to Assume the Troy Central Franchise Agreement [Docket No. 172] Lehman ALI Inc.s Objection to Marriott International, Inc.s Motion for Limited Modification of the Automatic Stay to Complete De-Identification of the Troy Central Residence Inn by Marriott Hotel [Docket No. 236] Notice of Presentment of Stipulation Between Innkeepers USA Trust and Marriott International, Inc. and Order Approving Settlement of Marriotts Motion for Limited Modification of the Automatic Stay and Debtors Motion to Assume the Troy Central Franchise Agreement [Docket No. 317]

f.

Status: This matter is going forward on a contested basis. II. Hearing Scheduled for August 31, 2010 at 2:00 p.m. (prevailing Eastern Time) A. Finance Motions 2. Cash Collateral 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. 361, 362, and 363, (B) to the Extent Approved in the Final Order, Granting Senior Secured, Priming Liens on Certain 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] Cash Management Debtors Motion for the Entry of an Order Authorizing the Continued Use of (I) Existing Cash Management System, as Modified Herein, (II) Existing Bank Accounts, (III) Existing Business Forms, and (IV) Certain Existing Investment Guidelines [Docket No. 14]

3.

Responses Received (to Cash Collateral and Cash Management motions): a. Midland Loan Services, Inc.s, Special Servicer for the Fixed Rate Trustee, Objection to (1) the Motion (A) Authorizing the Debtors to (i) Use the Adequate Protection Parties Cash Collateral and (ii) Providing Adequate Protection to the Adequate Protection Parties Pursuant to 11 U.S.C. 361, 362, and 363 and (B) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) and (2) Motion for Entry of an Order Authorizing the Continued Use of (I) Existing Cash Management System, as Modified Herein, (II) 4
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Existing Bank Accounts, (III) Existing Business Forms, and (IV) Certain Existing Investment Guidelines [Docket No. 36] Declaration of Ronald F. Greenspan in Support of Midland Loan Services, Inc.s, Special Servicer for the Fixed Rate Trustee, Objection to the Motion (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. 361, 362, and 363 and (B) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) and (2) Motion for Entry of an Order Authorizing the Continued Use of (I) Existing Cash Management System, as Modified Herein, (II) Existing Bank Accounts, (III) Existing Business Forms, and (IV) Certain Existing Investment Guidelines [Docket No. 37] b. Objection of C-III Asset Management LLC to Debtors (1) Motion for the Entry of Final Order Authorizing the Debtors to use the Adequate Protection Parties Cash Collateral and (2) Motion for Entry of an Order Authorizing the Continued Use of Existing Cash Management System, as Modified [Docket No. 254] Objection of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 to Debtors Motion for the Entry of a Final Order (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. 361, 362, and 363, (B) to the Extent Approved in the Final Order, Granting Senior Secured, Priming Liens on Certain Postpetition Intercompany Claims, and (C) to the Extent Approved in the Final Order, Granting Administrative Priority Status to Certain Postpetition Intercompany Claims and Joinder to the Objection of Midland Loan Services, Inc. [Docket No. 255] Declaration of Edward C. Brown in Support of the Objections of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 [Docket No. 258] 5
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c.

d.

Objection of CWCapital Asset Management LLC to Debtors (1) Motion for the Entry of Final Order Authorizing the Debtors to Use the Adequate Protection Parties Cash Collateral and (2) Motion for Entry of an Order Authorizing the continued Use of Existing Cash Management System, As Modified [Docket No. 257] Amended Objection of Midland Loan Services, Inc., Special Servicer for the Fixed Rate Trustee to (1) the Motion (A) Authorizing the Debtors to (i) use the Adequate Protection Parties Cash Collateral and (ii) Providing Adequate Protection to the Adequate Protection Parties Pursuant to 11 U.S.C. 361, 362, and 363 and (B) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) and (2) Motion for Entry of an Order Authorizing the Continued Use of (I) Existing Cash Management System, as Modified Herein, (II) Existing Bank Accounts, (III) Existing Business Forms, and (IV) Certain Existing Investment Guidelines [Docket No. 259] Omnibus Limited Objection of the Official Committee of Unsecured Creditors to the Debtors Motions to Authorize the Debtors to (I) Use Cash Collateral, (II) Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc., and (III) Obtain Postpetition Financing from Five Mile Capital Partners [Docket No. 265] Appaloosa Investment L.P. Is Objection 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, (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); and (II) Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 279]

e.

f.

g.

Replies Received (to Cash Collateral and Cash Management motions): h. Debtors Omnibus Reply in Support of the Debtors Cash Collateral Motion, Cash Management Motion, Lehman DIP Motion, and Five Mile DIP Motion, and in Response to Objections Thereto [Docket No. 337]

6
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Declaration of Nathan Cook, Chief Financial Officer of Innkeepers USA Trust, in Support of the Debtors Cash Collateral Motion and Cash Management Motion and in Response to Objections Thereto [Docket No. 338] Supplemental Declaration of Nathan Cook, Chief Financial Officer of Innkeepers USA Trust, in Support of the Debtors Cash Collateral Motion and Cash Management Motion and in Response to Objections Thereto [Docket No. 350] i. Lehman ALI Inc.s Joinder in Debtors Replies to Objections to Matters Scheduled for Hearing on September 1, 2010 [Docket No. 342]

Related Documents (to Cash Collateral and Cash Management motions): j. Interim Order (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. 361, 362, and 363, and (B) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) [Docket No. 54] Order Setting Final Hearing Date for Cash Collateral and Deadline to File Objections Thereto [Docket No. 72] Supplement to Debtors Motion for the Entry of Final Order (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. 361, 362, and 363, (B) to the Extent Approved in the Final Order, Granting Senior Secured, Priming Liens on Certain Postpetition Intercompany Claims, and (C) to the Extent Approved in the Final Order, Granting Administrative Priority Status to Certain Postpetition Intercompany Claims [Docket No. 310] Lehman ALI Inc.s Reservation of Rights with Respect to the Debtors Motion for an Order (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. 361, 362, and 363, and (B) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) [Docket No. 349]

k. l.

m.

Status: These matters are going forward on a contested basis. 4. Five Mile Capital DIP Debtors Motion for Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from Five Mile Capital Partners on a Priming Basis Pursuant to Sections 364(c)(1), 7
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364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 24] Responses Received: a. Omnibus Limited Objection of the Official Committee of Unsecured Creditors to the Debtors Motions to Authorize the Debtors to (I) Use Cash Collateral, (II) Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc., and (III) Obtain Postpetition Financing from Five Mile Capital Partners [Docket No. 265] Objection of Ad Hoc Committee of Preferred Shareholders to (I) Debtors Motion for Order Authorizing Debtors to Assume Plan Support Agreement and (II) Debtors Motion for Entry of Order Authorizing Debtors to Obtain Postpetition Financing from Five Mile Capital Partners on a Priming Basis [Docket No. 269] Limited Objection of Certain Prepetition Lenders to Debtors Motion for the Entry of an Order Authorizing Debtors to Obtain Postpetition Financing from Five Mile Capital Partners on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), and 364(e) of the Bankruptcy Code [Docket No. 311]

b.

c.

Replies Received: d. Debtors Omnibus Reply in Support of the Debtors Cash Collateral Motion, Cash Management Motion, Lehman DIP Motion, and Five Mile DIP Motion, and in Response to Objections Thereto [Docket No. 337] Declaration of William Q. Derrough in Support of the Debtors Five Mile DIP Motion and Lehman DIP Motion and in Response to Objections Thereto [Docket No. 339] e. Lehman ALI Inc.s Joinder in Debtors Replies to Objections to Matters Scheduled for Hearing on September 1, 2010 [Docket No. 342]

Related Documents: f. Supplement to the Debtors Motion for the Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from Five Mile Capital Partners on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 201]

Status: This matter is going forward on a contested basis. 8

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III. Hearing Scheduled for September 1, 2010 at 8:30 a.m. (prevailing Eastern Time) A. Finance Motions (contd) 5. Lehman DIP Debtors Motion for Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 23]

Responses Received: a. Omnibus Limited Objection of the Official Committee of Unsecured Creditors to the Debtors Motions to Authorize the Debtors to (I) Use Cash Collateral, (II) Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc., and (III) Obtain Postpetition Financing from Five Mile Capital Partners [Docket No. 265] Limited Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for the Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 267] Omnibus Declaration of Travis Shelhorse in Support of: (I) Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief; and (II) Limited Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for the Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 272] c. Local Texas Tax Authorities Objection to Debtors Motion for the Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 287]

b.

Replies Received: d. Debtors Omnibus Reply in Support of the Debtors Cash Collateral Motion, Cash Management Motion, Lehman DIP Motion, and Five Mile DIP Motion, and in Response to Objections Thereto [Docket No. 337] 9
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Declaration of William Q. Derrough in Support of the Debtors Five Mile DIP Motion and Lehman DIP Motion and in Response to Objections Thereto [Docket No. 339] e. Lehman ALI Inc.s Joinder in Debtors Replies to Objections to Matters Scheduled for Hearing on September 1, 2010 [Docket No. 342]

Related Documents: f. Supplement to the Debtors Motion for Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 200]

Status: This matter is going forward on a contested basis. B. Plan Support Agreement Assumption Motion 6. Plan Support Agreement Debtors Motion for Entry of an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 15]

Responses Received: a. Objection Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief and Joinder to the Objection of Midland Loan Services, Inc. [Docket No. 256] Declaration of Edward C. Brown in Support of the Objections of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 [Docket No. 258]

10
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b.

Objection of Midland Loan Services, Inc. to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 260] Reservation of Rights of the Official Committee of Unsecured Creditors in Response to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 264] Objection of Ad Hoc Committee of Preferred Shareholders to (I) Debtors Motion for Order Authorizing Debtors to Assume Plan Support Agreement and (II) Debtors Motion for Entry of Order Authorizing Debtors to Obtain Postpetition Financing from Five Mile Capital Partners on a Priming Basis [Docket No. 269] Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 271] Omnibus Declaration of Travis Shelhorse in Support of: (I) Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief; and (II) Limited Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for the Entry of an Order Authorizing the Debtors to Obtain Postpetition Financing from an Affiliate of Lehman ALI Inc. on a Priming Basis Pursuant to Sections 364(c)(1), 364(c)(2), 364(c)(3), 364(d)(1), and 364(e) of the Bankruptcy Code [Docket No. 272]

c.

d.

e.

f.

Joinder of C-III Asset Management LLC to Objections of Midland Loan Services, Inc. and LNR Partners, LLC to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 275] Joinder of CWCapital Asset Management LLC with Objections of Midland Loan Services, Inc. and LNR Partners, LLC to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 276] Appaloosa Investment L.P. Is Objection 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 11

g.

h.

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Extent Approved in the Final Order, Granting Senior Secured, Priming liens on Certain 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); and (II) Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 279] i. Objection of Five Mile Capital Partners LLC to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 280] Corrected Objection of Trimont Real Estate Advisors, Inc., as Special Servicer, to Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief [Docket No. 292]

j.

Replies Received: k. Debtors Omnibus Reply in Support of Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Further Relief and Response to Objections Thereto [Docket No. 340] Declaration of Marc Beilinson in Support of the Debtors Motion for an Order (A) Authorizing the Debtors to Assume the Plan Support Agreement and (B) Granting Related Relief and in Response to Objections Thereto [Docket No. 341] l. Lehman ALI Inc.s Joinder in Debtors Replies to Objections to Matters Scheduled for Hearing on September 1, 2010 [Docket No. 342]

Status: This matter is going forward on a contested basis. C. Ad Hoc Committee Examiner Motion 7. Appointment of Examiner Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 179]

Responses Received: a. Response to Motion for Appointment of Examiner [Docket No. 253] 12
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b.

Objection of the Official Committee of Unsecured Creditors to the Motion of the Ad Hoc Committee of Preferred Shareholders for an Order Directing the Appointment of an Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 263] Response of the United States Trustee to Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing the Appointment of Examiner Pursuant to Sections 1104(c)(1) and (2) of the Bankruptcy Code [Docket No. 268] Lehman ALI Inc.s Objection to Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code and Joinder in Debtors Objection to Motion [Docket No. 270] Objection of Apollo Investment Corporation to Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 277] Joinder of Wells Fargo Bank, N.A., as Trustee for the Registered Holders of Credit Suisse First Boston Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2007-C1 and U.S. Bank National Association, as Trustee for the Registered Holders of ML-CFC Commercial Mortgage Trust 2006-4, Commercial Mortgage Pass-Through Certificates, Series 2006-4 to Midland Loan Services, Inc.s Amended Objection to Motion of Ad hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 282] Debtors Objection to Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 285] Declaration of Nathan J. Cook, Chief Financial Officer of the Debtors, in Support of Debtors Objection to Motion of Ad Hoc Committee of Preferred Shareholders for Order Directing Appointment of Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 286]

c.

d.

e.

f.

g.

Replies Received: h. Reply of Ad Hoc Committee of Preferred Shareholders to Objections to Motion for Order Directing Appointment of 13
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Examiner Pursuant to Section 1104(c)(1)-(2) of the Bankruptcy Code [Docket No. 334] Status: This matter is going forward on a contested basis. New York, New York Dated: August 30, 2010 /s/ Paul M. Basta James H.M. Sprayregen, P.C. Paul M. Basta Jennifer L. Marines 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. (admitted pro hac vice) 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

14
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