10000004424

Hearing Date: April 28, 2011 at 10:00 a.m. (ET) Response Deadline: April 21, 2011 at 4:00 p.m.
(ET)
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon 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 HEARING ON DEBTORS SECOND OMNIBUS OBJECTION TO CERTAIN DUPLICATIVE PROOFS OF CLAIM PLEASE TAKE NOTICE that a hearing (the Hearing)2 for the relief requested in the above-referenced objection (the Objection) will be held before the Honorable Shelley C.
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.
K&E 18515240
Chapman, United States Bankruptcy Judge, in Courtroom No. 610 of the United States Bankruptcy Court for the Southern District of New York (the Court), Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408, on April 28, 2011 at 10:00 a.m. prevailing Eastern Time or such other time as counsel may be heard. PLEASE TAKE FURTHER NOTICE that any responses to the Objection: (a) must be in writing; (b) shall conform to the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), all General Orders of the Court, the Local Rules for the United States Bankruptcy Court for the Southern District of New York, and the Notice, Case Management, and Administrative Procedures [Docket No. 68] (the Case Management Procedures) approved by the Court; (c) 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 (d) shall be served to as to be actually received no later than April 21, 2011 at 4:00 p.m. prevailing Eastern Time by the entities on the Master Service List (as such term is defined in the Case Management Procedures), which is available at www.omnimgt.com/innkeepers, the website maintained by Omni Management Group, LLC, the Debtors notice and claims agent. Only those responses that are timely filed, served, and received will be considered.
All capitalized terms used but otherwise not defined herein shall have the meanings set forth in the Motion.
New York, New York Dated: March 29, 2011
/s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon 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
Hearing Date: April 28, 2011 at 10:00 a.m. (ET) Response Deadline: April 21, 2011 at 4:00 p.m. (ET)
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon 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
DEBTORS SECOND OMNIBUS OBJECTION TO CERTAIN DUPLICATIVE PROOFS OF CLAIM
THIS OBJECTION SEEKS TO DISALLOW AND EXPUNGE CERTAIN FILED PROOFS OF CLAIM. CLAIMANTS RECEIVING THIS
OBJECTION SHOULD LOCATE THEIR NAMES AND CLAIMS ON SCHEDULE 1 TO EXHIBIT A ATTACHED TO THIS OBJECTION
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
Innkeepers USA Trust and certain of its affiliates, as debtors and debtors in possession (collectively, the Debtors) object (this Objection) to certain duplicative proofs of Claim (as defined below) listed on Schedule 1 to Exhibit A annexed hereto (the Disputed Claims) and seek entry of an order, substantially in the form attached hereto as Exhibit A, disallowing and expunging such Disputed Claims, pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code) and Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules). In support of this Objection, the Debtors respectfully state as follows: Jurisdiction 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334. This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). 2. 3. Venue is proper in this Court pursuant to 28 U.S.C. 1408 and 1409. The bases for the relief requested herein are sections 105(a) and 502(b) of the
Bankruptcy Code and Bankruptcy Rule 3007. Background 4. On July 19, 2010 (the Petition Date), each of the Debtors filed a petition with
the Court under chapter 11 of the Bankruptcy Code (collectively, the Chapter 11 Cases). The Chapter 11 Cases have been consolidated for procedural purposes only and are being jointly administered pursuant to Bankruptcy Rule 1015(b). The Debtors are operating their business and managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No request for the appointment of a trustee has been made in the Chapter 11
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.
Cases. On July 28, 2010, the United States Trustee for the Southern District of New York (the U.S. Trustee) appointed an official committee of unsecured creditors (the Creditors Committee). 5. Additional information regarding the Debtors business, capital structure, and the
circumstances leading to the Chapter 11 Cases is contained in the Amended Declaration of Dennis Craven, Chief Financial Officer of Innkeepers USA Trust, in Support of First Day Pleadings [Docket No. 33, as supplemented by Docket No. 516]. Claims Reconciliation Process 6. On or around September 1, 2010, the Debtors filed their statements of financial
affairs and schedules of assets and liabilities, current income and expenditures, and executory contracts and unexpired leases as required by section 521 of the Bankruptcy Code (collectively, the Schedules). 7. On September 16, 2010, the Court entered an order (the Bar Date Order)
[Docket No. 440] establishing certain dates and deadlines for filing proofs of claim in the Chapter 11 Cases. Specifically, among other things, the Court established: (a) October 29, 2010 (the General Bar Date), as the deadline for all persons and entities holding or wishing to assert a claim (as defined in section 101(5) of the Bankruptcy Code) against any of the Debtors that arose prior to the Petition Date (each, a Claim), including any claim arising under section 503(b)(9) of the Bankruptcy Code, to file proof of such Claim in writing; and (b) January 18, 2011 (the Governmental Bar Date), as the deadline for all governmental units holding or wishing to assert a Claim against any of the Debtors that arose prior to the Petition Date to file proof of such Claim in writing.
8.
To date, entities have filed nearly 2,000 proofs of claim against the Debtors on an
aggregate basis, pursuant to which such entities assert more than $6.75 billion in aggregate liabilities. Objection 9. This Objection relates to the Disputed Claims identified on Schedule 1 to
Exhibit A that are duplicates of another proof of Claim (the Surviving Claims) as identified on Schedule 1 to Exhibit A. The Debtors object to the allowance of each Disputed Claim because it would provide for a double recovery from the Debtors on account of the same Claim and thus is unenforceable against the Debtors. The Disputed Claims should be disallowed and expunged from the Debtors Claims register. Relief Requested 10. By this Objection and pursuant to section 502 of the Bankruptcy Code and
Bankruptcy Rule 3007, the Debtors request that the Court enter an order disallowing and expunging the Disputed Claims identified on Schedule 1 to Exhibit A. Basis for Relief 11. A filed proof of claim is deemed allowed unless a party in interest objects thereto.
See 11 U.S.C. 502(a); see also id. 1111(a) (A proof of claim . . . is deemed filed under section 501 of this title for any claim . . . that appears in the schedules . . . except a claim . . . that is scheduled as disputed, contingent, or unliquidated.). If an objection refuting at least one of the claims essential allegations is asserted, the claimant has the burden to demonstrate validity of the claim. See, e.g., Sherman v. Novak (In re Reilly), 245 B.R. 768, 773 (2d Cir. BAP 2000); In re Rockefeller Ctr. Props., 272 B.R. 524, 539 (Bankr. S.D.N.Y. 2000); In re St. Johnsbury Trucking Co., 206 B.R. 318. 323 (Bankr. S.D.N.Y. 1997).
12.
Following a thorough review of the Claims filed by the applicable Bar Date(s),
the Debtors have determined that the Disputed Claims are duplicative of other Claims that have been filed and should not be enforced against the Debtor against which each such Disputed Claim is asserted, and thus should be disallowed. The Debtors object to each Disputed Claim on the basis that the claimant should not obtain multiple recoveries on a single Claim. 13. For the reasons stated above, the Debtors object to the allowance of the Disputed
Claims and the Debtors respectfully request this Court enter an order disallowing and expunging the Disputed Claims such that only one proof of each Claim remainsthe Surviving Claims reflecting the respective amounts claimed. Motion Practice 14. This Objection includes citations to the applicable rules and statutory authorities
upon which the relief requested herein is predicated and a discussion of their application to this Objection. Accordingly, the Debtors submit that this Objection satisfies Rule 9013-1(a) of the Local Rules of Bankruptcy Procedure for the Southern District of New York. Reservation of Rights 15. This Objection is limited to the grounds stated herein. Accordingly, it is without
prejudice to the rights of the Debtors or any other party in interest to object to any of the Disputed Claims or any of the Surviving Claims on any ground whatsoever and the Debtors expressly reserve all further substantive and/or procedural objections they may have. Notice 16. The Debtors have provided notice of this Motion to the entities on the Master
Service List (as such term is defined in the Notice, Case Management, and Administrative Procedures [Docket No. 68]), which is available at www.omnimgt.com/innkeepers, the website
maintained by Omni Management Group, LLC, the Debtors notice and claims agent. The Debtors respectfully submit that no further notice is necessary.
WHEREFORE, the Debtors respectfully request that the Court (a) enter an order disallowing and expunging the Disputed Claims listed on Schedule 1 to Exhibit A and (b) grant such other and further relief as is just and proper. New York, New York Dated: March 29, 2011 /s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon 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
Exhibit A Proposed Order
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon 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 Street Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 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
ORDER GRANTING DEBTORS SECOND OMNIBUS OBJECTION TO CERTAIN DUPLICATIVE PROOFS OF CLAIM Upon the Debtors Second Omnibus Objection to Certain Duplicative Proofs Of Claim (the Objection)2 filed by Innkeepers USA Trust and certain of its affiliates, as debtors and debtors in possession (collectively, the Debtors) requesting entry of an order disallowing and
1
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. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Objection.
expunging the Disputed Claims listed on Schedule 1 attached hereto, pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code) and Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules); all as more fully described in the Objection; 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. 2. The Objection is granted to the extent set forth herein. The Disputed Claims listed on Schedule 1 attached hereto are hereby disallowed
and expunged in their entirety pursuant to section 502(b) of the Bankruptcy Code. 3. The Surviving Claims will remain on the Claims register, and such Claims are
neither allowed nor disallowed at this time, subject, however to any future objection on any basis. 4. The disallowance and expungement of the Disputed Claims does not constitute
any admission or finding with respect to any of the Surviving Claims. 5. The terms and conditions of this Order shall be immediately effective and
enforceable upon its entry. 6. All time periods set forth in this Order shall be calculated in accordance with
Bankruptcy Rule 9006(a).
7.
The Debtors are authorized to take all actions necessary to effectuate the relief
granted pursuant to this Order in accordance with the Motion. 8. This Court retains jurisdiction with respect to all matters arising from or related to
the implementation of this Order. New York, New York Dated: _________________, 2011
Honorable Shelley C. Chapman United States Bankruptcy Judge
Schedule 1 Duplicative Claims
Second Omnibus Objection
Exhibit A Duplicative Claims

Debtor Innkeepers USA Trust Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $805.00
In re:Innkeepers USA Trust Case No 10-13800
Claim #
Total $805.00
Claim To Be Disallowed Filed On:
323 9/27/2010
Creditor:
ANHEUSER-BUSCH OF DENVER MELISSA OCEPEK 1455 EAST 62ND AVE DENVER, CO 80216
Remaining Claim Filed On:
12
Innkeepers USA Trust
ANHEUSER-BUSCH OF DENVER MELISSA OCEPEK 1455 EAST 62ND AVE DENVER, CO 80216
$0.00
$0.00
$0.00
$805.00
$805.00
8/2/2010
289 9/23/2010
Grand Prix San Jose LLC
Creditor:
$0.00
$0.00
$0.00
$1,228.00
$1,228.00
AUTHORITY LOCKSMITH SERVICES EDMUNDO RIVAS 6040 BRITTANY AVE NEWARK, CA 94560
103
Grand Prix San Jose LLC
AUTHORITY LOCKSMITH SERVICES EDMUNDO RIVAS 6040 BRITTANY AVE NEWARK, CA 94560
$0.00
$0.00
$0.00
$1,228.00
$1,228.00
8/16/2010
Page 1

Debtor Innkeepers USA Trust Name and Address of Claimant Secured $0.00 Administrative $1,115.12 Priority $0.00 Unsecured $0.00
Claim #
Total $1,115.12
936 10/27/2010
Creditor:
AUTOCRAT INC. ATTN: TINA DRITT 10 BLACKSTONE VALLEY PLACE LINCOLN, RI 02865
24
$0.00
$1,115.12
$0.00
$0.00
$1,115.12
8/2/2010
943 10/27/2010
Creditor:
$0.00
$1,353.76
$0.00
$0.00
$1,353.76
25
$0.00
$1,353.76
$0.00
$0.00
$1,353.76
8/2/2010
1232 10/27/2010
Creditor:
$0.00
$0.00
$0.00
$22,053.80
$22,053.80
BEST WESTERN INTERNATIONAL INC Attn: Michael G. Helms 6201 North 24th Parkway Phoenix, AZ 85016
923
BEST WESTERN INTERNATIONAL INC Attn: Michael G. Helms 6201 North 24th Parkway Phoenix, AZ 85016
$0.00
$0.00
$0.00
$22,053.80
$22,053.80
10/27/2010
Page 2

Debtor KPA Leaseco, Inc. Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $50,000,000.00
Claim #
Total $50,000,000.00
1341 10/29/2010
Creditor:
BRENDA ALLERHEILIGEN ATTN: DAVID S. JENNIS 400 N. ASHLEY DRIVE, SUITE 2540 TAMPA, FL 33602
1324
KPA Leaseco, Inc.
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
10/29/2010
1386 10/29/2010
KPA/GP Ft. Walton LLC
Creditor:
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
1382
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
10/29/2010
1422 10/29/2010
Innkeepers USA Limited Partnership
Creditor:
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
Remaining Claim
1409
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
Filed On:
10/29/2010
Page 3

Claim #
Total $245.16
362 9/28/2010
Creditor:
CURCIO PRINTING Curcio Printing Services 513 PRENTICE RD. VESTAL, NY 13850
70
CURCIO PRINTING Curcio Printing Services 513 PRENTICE RD. VESTAL, NY 13850
$0.00
$0.00
$0.00
$245.16
$245.16
8/2/2010
708 10/19/2010
Grand Prix Fixed Lessee LLC
Creditor:
$0.00
$0.00
$0.00
$470.89
$470.89
D&L SUPPLY ATTN: DONITA ZELLER P.O. BOX 1076 AUBURN, WA 98071
317
D&L SUPPLY ATTN: DONITA ZELLER P.O. BOX 1076 Auburn, WA 98071
$0.00
$0.00
$0.00
$470.89
$470.89
9/27/2010
Page 4

Debtor KPA Leaseco, Inc. Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $50,000,000.00
Claim #
Total $50,000,000.00
1370 10/29/2010
Creditor:
DAVID MOBLEY ATTN: DAVID S. JENNIS 400 N. ASHLEY DRIVE, SUITE 2540 TAMPA, FL 33602
1354
KPA Leaseco, Inc.
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
10/29/2010
1394 10/29/2010
Creditor:
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
1388
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
10/29/2010
1447 10/29/2010
Creditor:
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
Remaining Claim
1433
$0.00
$0.00
$0.00
$50,000,000.00
$50,000,000.00
Filed On:
10/29/2010
Page 5

Debtor Grand Prix Fixed Lessee LLC Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $3,292.58
Claim #
Total $3,292.58
1200 10/21/2010
Creditor:
E P COMMERCIAL LAUNDRY ATTN: ERIC P PIKE 315 S. DELSEA DR, SUITE E-15 CLAYTON, NJ 08312
760
E P COMMERCIAL LAUNDRY ATTN: ERIC P. PIKE 315 S. DELSEA DR, SUITE E-15 CLAYTON, NJ 08312
$0.00
$0.00
$0.00
$3,292.58
$3,292.58
10/21/2010
1529 10/29/2010
Creditor:
$0.00
$0.00
$0.00
$32,081.00
$32,081.00
JENKINS/GALES & MARTINEZ, INC. JEANNETTE M. CONRAD 2 PRUDENTIAL PLAZA 180 N. STETSON AVE., STE. 4525 CHICAGO, IL 60601
1528
JENKINS/GALES & MARTINEZ, INC. JEANNETTE M. CONRAD 2 PRUDENTIAL PLAZA 180 N. STETSON AVE., STE. 4525 CHICAGO, IL 60601
$0.00
$0.00
$0.00
$32,081.00
$32,081.00
10/29/2010
1225 10/25/2010
Creditor:
$0.00
$0.00
$0.00
$4,098.33
$4,098.33
KENTUCKY UTILITIES COMPANY ATTN: JON WINFREY ONE QUALITY STREET LEXINGTON, KY 40507
879
KENTUCKY UTILITIES COMPANY ATTN: JON WINFREY ONE QUALITY STREET LEXINGTON, KY 40507
$0.00
$0.00
$0.00
$4,098.33
$4,098.33
10/26/2010
Page 6

Claim #
Total $556.00
1241 10/27/2010
Creditor:
KING JUICE CO. / RICHARD DUMKE ATTN: ESTELLE DUMKE P.O. BOX 4419 CRESTLINE, CA 92325
56
KING JUICE CO. / RICHARD DUMKE ATTN: ESTELLE DUMKE P.O. BOX 4419 Crestline, CA 92325
$0.00
$0.00
$0.00
$556.00
$556.00
8/3/2010
1197 10/27/2010
KPA RIGG, LLC
Creditor:
$0.00
$0.00
$0.00
$3,537.85
$3,537.85
LODGENET INTERACTIVE ATTN: ISOLDE KONDERT 3900 W INNOVATION ST SIOUX FALLS, SD 57107
1169
KPA RIGG, LLC
LODGENET INTERACTIVE ATTN: ISOLDE KONDERT 3900 W INNOVATION ST SIOUX FALLS, SD 57107
$0.00
$0.00
$0.00
$3,537.85
$3,537.85
10/27/2010
542 10/5/2010
Innkeepers USA Trust, et al.
Creditor:
$0.00
$0.00
$0.00
$658.27
$658.27
METRO APPLIANCE SERVICE JUDY MILLER 1640 S. BROADWAY DENVER, CO 80210
137
METRO APPLIANCE SERVICE JUDY MILLER 1640 S. BROADWAY DENVER, CO 80210
$0.00
$0.00
$0.00
$658.27
$658.27
8/24/2010
Page 7

Debtor Innkeepers USA Trust Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $2,238.22 Unsecured $0.00
Claim #
Total $2,238.22
516 10/4/2010
Creditor:
MGE ELECTRIC SERVICES INC. JESUS RODRIGUEZ P.O. BOX 772157 ORLANDO, FL 32877
169
MGE ELECTRIC SERVICES INC. JESUS RODRIGUEZ P.O. BOX 772157 ORLANDO, FL 32877-2157
$0.00
$0.00
$2,238.22
$0.00
$2,238.22
8/30/2010
1251 10/27/2010
Grand Prix Floating Lessee LLC
Creditor:
$0.00
$0.00
$0.00
$879.38
$879.38
POST, POLAK, GOODSELL, MACNEILL Attn: Paul Strauchler, Esq. 425 Eagle Rock Ave., Suite 200 Roseland, NJ 07068
Remaining Claim
1246
Grand Prix Floating Lessee LLC
POST, POLAK, GOODSELL, MACNEILL Attn: Paul Strauchler, Esq. 425 Eagle Rock Ave., Suite 200 Roseland, NJ 07068
$0.00
$0.00
$0.00
$879.38
$879.38
Filed On:
10/27/2010
440 9/27/2010
Creditor:
$0.00
$0.00
$0.00
$2,250.22
$2,250.22
PRECISION DOORS & HARDWARE Attn: Randy Nolen 6809 - A Bowman's Crossing Frederick, MD 21703
53
PRECISION DOORS & HARDWARE, LLC RICHARD M. SISSMAN, ESQUIRE 600 JEFFERSON PLAZA SUITE 308 ROCKVILLE, MD 20852
$0.00
$0.00
$0.00
$2,250.22
$2,250.22
8/2/2010
Page 8

Debtor Grand Prix Fixed Lessee LLC Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $5,868.98
Claim #
Total $5,868.98
572 10/7/2010
Creditor:
PREMIER ELEVATOR CO., INC. JAMIE CONKLIN 230 ANDREW DRIVE Stockbridge, GA 30281
571
PREMIER ELEVATOR COMPANY INC JAMIE CONKLIN 230 ANDREW BLVD STOCKBRIDGE, GA 30281
$0.00
$0.00
$0.00
$5,868.98
$5,868.98
10/7/2010
1023 10/28/2010
Creditor:
$0.00
$0.00
$0.00
$1,234.10
$1,234.10
REGENCY CLEANERS ATTN: SURJIT MAKKAR 13904 TRINITY BLVD EULESS, TX 76040
Remaining Claim
856
REGENCY CLEANERS ATTN: SURJIT MAKKAR 13904 TRINITY BLVD EULESS, TX 75022
$0.00
$0.00
$0.00
$1,234.10
$1,234.10
Filed On:
10/25/2010
596 10/8/2010
Creditor:
$0.00
$0.00
$0.00
$6,380.13
$6,380.13
STAR CLEANER ATTN: DUNG LE 6810 208TH ST. SW SUITE B LYNNWOOD, WA 98036
143
STAR CLEANER ATTN: DUNG LE 6810 208TH ST. SW SUITE B LYNNWOOD, WA 98036
$0.00
$0.00
$0.00
$6,380.13
$6,380.13
8/24/2010
Page 9

Debtor Innkeepers USA Limited Partnership Name and Address of Claimant Secured $0.00 Administrative $0.00 Priority $0.00 Unsecured $460.43
Claim #
Total $460.43
501 10/4/2010
Creditor:
TOCOR LIGHTING PRODUCT JIM ROSENDAUL 4420 SHEPHERDSVILLE RD LOUISVILLE, KY 40218
Remaining Claim
184
TOCOR LIGHTING PRODUCT JIM ROSENDAUL 4420 SHEPHERDSVILLE RD LOUISVILLE, KY 40218
$0.00
$0.00
$0.00
$460.43
$460.43
Filed On:
9/2/2010
Claims To Be Disallowed Totals
26
$0.00
$2,468.88
$2,238.22
$300,086,100.12
$300,090,807.22
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Hearing Date: April 28, 2011 at 10:00 a.m. (ET) Response Deadline: April 21, 2011 at 4:00 p.m.

New York, New York Dated: March 29, 2011

DEBTORS SECOND OMNIBUS OBJECTION TO CERTAIN DUPLICATIVE PROOFS OF CLAIM

Exhibit A Proposed Order

Bankruptcy Rule 9006(a).

Honorable Shelley C. Chapman United States Bankruptcy Judge

Schedule 1 Duplicative Claims

Second Omnibus Objection

Exhibit A Duplicative Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Remaining Claim Filed On:

Innkeepers USA Trust

Claim To Be Disallowed Filed On:

Grand Prix San Jose LLC

Remaining Claim Filed On:

Grand Prix San Jose LLC

Second Omnibus Objection

Exhibit A Duplicative Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Remaining Claim Filed On:

Innkeepers USA Trust

Claim To Be Disallowed Filed On:

Innkeepers USA Trust

Remaining Claim Filed On:

Innkeepers USA Trust

Claim To Be Disallowed Filed On:

Innkeepers USA Trust

Remaining Claim Filed On:

Innkeepers USA Trust

Second Omnibus Objection

Exhibit A Duplicative Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Remaining Claim Filed On:

KPA Leaseco, Inc.

Claim To Be Disallowed Filed On:

KPA/GP Ft. Walton LLC

Remaining Claim Filed On:

KPA/GP Ft. Walton LLC

Claim To Be Disallowed Filed On:

Innkeepers USA Limited Partnership

Innkeepers USA Limited Partnership

Second Omnibus Objection

Exhibit A Duplicative Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Remaining Claim Filed On:

Innkeepers USA Trust

Claim To Be Disallowed Filed On:

Grand Prix Fixed Lessee LLC

Remaining Claim Filed On:

Grand Prix Fixed Lessee LLC

Second Omnibus Objection

Exhibit A Duplicative Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Remaining Claim Filed On:

KPA Leaseco, Inc.

Claim To Be Disallowed Filed On:

KPA/GP Ft. Walton LLC

Remaining Claim Filed On: