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) 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) Joint Administration Requested

MOTION OF LENARD M. PARKINS FOR ADMISSION PRO HAC VICE OF JOHN D. PENN Lenard M. Parkins (Movant), a member in good standing of the Bar of the State of New York, an attorney admitted to practice before the United States District Court for the Southern District of New York, and associated with Haynes and Boone, LLP (Haynes and Boone), hereby moves (the Motion) this Court for an order admitting John D. Penn (the Proposed Admittee) pro hac vice to represent Midland Loan Services, Inc., in this case pursuant to Rule 2090-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York (the Local Rules). In support of this Motion, Movant relies upon the respective certification of the Proposed Admittee which is attached as an exhibit hereto and respectfully represents as follows: 1. John D. Penn (john.penn@haynesboone.com) is a partner at Haynes and Boone.

Mr. Penn is a member in good standing of the Bar of the State of Texas and is admitted to practice before all state courts in Texas. Mr. Penn is admitted to practice before the United
MOTION FOR ADMISSION TO PRACTICE PRO HAC VICE
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States District Court for the Southern, Northern, Eastern and Western Districts of Texas, the United States Supreme Court, and the United States Court of Appeals for the Fifth Circuit. There are no disciplinary proceedings or criminal proceedings pending against Mr. Penn in any jurisdiction and there have been no disclosure of any pending grievances against him. The Certification of Mr. Penn is attached hereto as Exhibit A in support of the Motion. 2. Movant requests that this Court approve the Motion so that the Proposed

Admittee may file pleadings, appear and be heard at hearings, and otherwise represent Midland Loan Services, Inc. in this case. WHEREFORE, Movant respectfully requests that the Court: (a) enter an order admitting the Proposed Admittee pro hac vice to Midland Loan

Services, Inc. in this case; and (b) grant such other and further relief as is just and proper.

Dated: July 19, 2010 HAYNES AND BOONE, LLP Attorneys for Midland Loan Services, Inc. /s/ Lenard M. Parkins Lenard M. Parkins (NY Bar #4579124) 1221 Avenue of the Americas 26th Floor New York, NY 10020 Telephone: (212) 659-7300 Facsimile: (212) 918-8989

MOTION FOR ADMISSION TO PRACTICE PRO HAC VICE

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Exhibit A

HAYNES AND BOONE, LLP 1221 Avenue of the Americas, 26th Floor New York, New York 10020 Telephone: (212) 659-7300 Facsimile: (212) 884-8211 Lenard M. Parkins (NY Bar # 4579124) 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) Joint Administration Requested

CERTIFICATION OF JOHN D. PENN I, John D. Penn, in support of the Motion of Lenard M. Parkins Admission Pro Hac Vice of John D. Penn do hereby certify under penalty of perjury as follows: 1. 2. I am eligible for admission pro hac vice to this Court. I am a partner at the law firm of Haynes and Boone, LLP and maintain an office

for the practice of law at 201 Main Street, Suite 2200, Fort Worth, Texas, 76102. 3. I am a member in good standing of the Bar of the State Texas, and have been

admitted to practice before the United States District Courts for the Southern, Northern, Eastern and Western Districts of Texas, the United States Supreme Court, and the United States Court of Appeals for the Fifth Circuit. There are no disciplinary proceedings or criminal proceedings pending against me and there have been no disclosures of any pending formal grievances against me.

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4.

I submit to the disciplinary jurisdiction of this Court for any alleged misconduct

which occurs in the course of my representation of Midland Loan Services, Inc., pursuant to Rule 2090-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York (the Local Rules). 5. I have access to, or have acquired, a copy of the Local Rules of this Court, am

generally familiar with such Rules, and will comply with such Rules. I certify under penalty of perjury that the foregoing is true and correct. Executed on July 19, 2010. HAYNES AND BOONE, LLP
Attorneys for Midland Loan Services, Inc.

/s/ John D. Penn John D. Penn 201 Main Street, Suite 2200 Fort Worth, TX 76102 Telephone: (817) 347-6610 Facsimile: (817) 348-2300

2
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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al., Debtors. ) ) ) ) ) ) ) Chapter 11 Case No. 10-13800 (SCC) Joint Administration Requested

ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE OF JOHN D. PENN Upon the Motion (the Motion) of Lenard M. Parkins seeking the admission pro hac vice of John D. Penn to represent Midland Loan Services, Inc. in this case; and upon consideration of the Motion, the Certification of John D. Penn; and the Court having jurisdiction to consider the Application and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; and after due deliberation and sufficient cause appearing therefore, it is ORDERED that John D. Penn is admitted pro hac vice to represent Midland Loan Services, Inc. and other entities that she and his firm may represent in the above-captioned case and may appear in this case and any related proceedings pro hac vice; and it is further Dated: July ____, 2010 New York, New York ____________________________________ UNITED STATES BANKRUPTCY JUDGE

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