UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

In re:
INNKEEPERS USA TRUST, et al.,
Debtors.
)
)
)
)
)
)
____________________________ )
Chapter I I
Case No. 10-13800 (SCC)
Jointly Administered
DECLARATION OF DISINTERESTEDNESS
OF CLARK HILL PLC IN SUPPORT OF
RETENTION AS ORDINARY COURSE PROFESSIONAL
Tina M. Bird being duly sworn, upon her oath, deposes and says:
I. I am a member of Clark Hill, PLC, located at I 50 North Michigan Avenue,
Suite 2700, Chicago, Illinois, 60601 (the "Firm")
2. The above-captioned debtors (collectively, the "Debtors") have requested that
the Firm provide legal services to the Debtors, and the Firm has consented to provide such
services.
3. The Firm may have performed services in the past, may currently perform
services and may perform services in the future, in matters unrelated to these chapter I I
cases, for entities that are parties in interest in the Debtors' chapter I I cases. The Firm does
not perform services for any such person in connection with these chapter I I cases, or have
any relationship with any such person, their attorneys, or accountants that would be adverse
to the Debtors or their estates, with respect to the matter on which the Firm is being
employed.
4. As part of its customary practice, the Firm is retained in cases, proceedings,
and transactions involving many different parties, some of whom may represent or be
6784046.1 33957/133672
retained by the Debtors, claimants and parties in interest in these chapter II cases.
5. Neither I, nor any principal, partner, director or officer of, or professional
retained by the Firm has agreed to share or will share any portion of the compensation to be
received from the Debtors with any other person other than the principal and regular
employees of the Firm.
6. Neither I, nor any principal, partner, director or officer of, or professional
retained by the Firm, insofar as I have been able to ascertain, holds or represents any interest
adverse to the Debtors or their estates with respect to the matter(s) upon which this Firm is
to be retained.
7. The Debtors owe the Firm $7,245.00 for prepetition services, the payment of
which is subject to limitations contained in the Bankruptcy Code, II U.S.C. 101-1532.
8. The Firm is conducting further inquiries regarding its retention by any
creditors of the Debtors, and upon conclusion of that inquiry, or at any time during the
period of its retention, if the Firm should discover any facts bearing on the matters described
herein, the Firm will supplement the information contained in this Declaration.
Dated: November 2, 20 I 0
6784046.133957/133672
Respectfully submitted,
CLARK HILL PLC
By: Is/Tina M. Bird
Clark Hill PLC
2
Tina M. Bird (6239012)
!50 N. Michigan Avenue, Suite 2700
Chicago, IL 6060 I
(312) 985-5900
tbird@clarkhill.com
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
)
In re: ) Chapter II
)
INNKEEPERS USA TRUST, et al., ) Case No. 10-13800 (SCC)
)
Debtors. ) Jointly Administered
___________________________ )
NOTICE OF FILING
PLEASE TAKE NOTICE on the 2"d day of November 20 I 0, we sent, via FedEx, to
be filed in the United States Bankruptcy Court for the Southern District of New York, the
attached Declaration of Disinterestedness of Clark Hill PLC in Support of Retention as
Ordinary Course Professional, a copy of which is attached hereto.
Dated: November 2, 20 I 0
6784046.133957/133672
Respectfully submitted,
CLARK HILL PLC
By: Is/Tina M. Bird
Clark Hill PLC
Tina M. Bird (6239012)
!50 N. Michigan Avenue, Suite 2700
Chicago, IL 6060 I
(312) 985-5900
tbird@clarkhill.com
PROOF OF SERVICE VL4 U.S. MAIL
I, Tina M. Bird, an attorney, certify that I served or caused to be served the attached
Notice of Filing and Declaration of Disinterestedness, to each party on the below Service
List at their designated addresses via U.S. Mail, proper postage affixed, from 150 N.
Michigan Ave., Suite 2700, Chicago, IL 6060 I, on or before 5:00 p.m., on November 2,
2010
Innkeepers USA Trust
Attn: Mark Murphy
340 Royal Poinciana Way #306
Palm Beach, FL 33480
Debtors
Office of the United States Trustee
Attn: Paul Schwartzberg
33 Whitehall Street, 21
51
Fir.
New York, NY York 10004
6784046.1339571133672
By: Is/Tina M. Bird
Clark Hill PLC
Tina M. Bird (6239012)
!50 N. Michigan Avenue, Suite 2700
Chicago, IL 60601
(312) 985-5900
tbird@clarkhill.com
SERVICE LIST
Clement Yee
Kirkland & Ellis LLP
60 I Lexington Ave.
New York, NY I 0022
Counsel for Debtors
Jordan Wishnew
Morrison & Foerster LLP
1290 Avenue of the Americas
New York, NY 10104
Counsel for The Official Committee of
Unsecured Creditors
CLARI<HILL
Hlan R. Stoneking
T 312.985.5921
f 312.985.5999
Email: estoneking@clarkhiiJ.com
BY FEDERAL EXPRESS
Clerk
US Bankruptcy Court
Southern District ofNew York
One Bowling Green
New York, NY 10004
212.668.2870
November 2, 2010
Re: In Re: Innkeepers USA Trust, et a!.,
Chapter 11
Dear Clerk:
Case No. 10-13800 (SCC)
Jointly Administered
Clark Hill PLC
150 North Michigan Avenue
Suite 2700
Chicago, Illinois 60601
T 312.985.5900
F 312.985.5999
darkhill.com
Relative to the above referenced matter, enclosed please find an original and one copy of
Clark Hill PLC's Declaration of Disinterestedness. Please return a file stamped copy to me in the
also enclosed self addressed stamped envelope. Thank you for your assistance.
ERS:es
Enclosure
6785710.1339571133672
Very truly yours,
CLARK HILL PLC

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