UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al.,11 Debtors.

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

ORDER FURTHER EXTENDING TIME TO FILE NOTICES OF REMOVAL OF ACTIONS Upon the motion (the Motion)2 of the Debtors, as debtors and debtors in possession (collectively, the Debtors), for the entry of an order (this Order) (a) further extending the period within which the Debtors may remove actions pursuant to 28 U.S.C. 1452 and Rule 9027 of the Federal Rules of Bankruptcy Procedure and (b) granting such other relief as is just and proper; it appearing that the relief requested is in the best interests of the Debtors estates, their creditors, and other parties in interest; the Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); venue being proper before this court pursuant to 28 U.S.C. 1408 and 1409; notice of the Motion having been adequate and appropriate under the circumstances; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. The Motion is granted to the extent provided herein.

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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The time by which the Debtors may file notices of removal in this Court with

respect to the Actions is extended to and includes the latest to occur of: (a) April 10, 2012; (b) the day that is 30 days after entry of an order terminating the automatic stay with respect to the particular Action sought to be removed; and (c) with respect to Postpetition Actions, the time periods set forth in Bankruptcy Rule 9027(a)(3). 3. This Order is without prejudice to the rights of the Debtors to request an

additional extension of time by which the Debtors may file notices of removal in this Court with respect to the Actions. 4. This Order shall be without prejudice to any position the Debtors may take

regarding whether section 362 of the Bankruptcy Code applies to any Action. 5. The Debtors are authorized to take all actions necessary to effectuate the relief

granted pursuant to this Order in accordance with the Motion. 6. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 7. The Court retains jurisdiction with respect to all matters arising from or related to

the implementation of this Order. New York, New York Dated: October 6, 2011 /s/ Shelley C. Chapman United States Bankruptcy Judge

All capitalized terms used by otherwise not defined herein shall have the meanings set forth in the Motion.

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