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U.S.

BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK MANHATTAN DIVISION


IN RE: INNKEEPERS USA TRUST, et al. Debtors. ______________________________________/ NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF NOTICES AND PAPERS PLEASE TAKE NOTICE that Zachary J. Bancroft, Esquire, of Lowndes, Drosdick, Doster, Kantor and Reed, P.A. hereby appears as counsel of record on behalf of Anand Enterprise, Inc., (Anand) a creditor of the Debtors and a party in interest in the above-referenced case. Such counsel hereby enters his appearance pursuant to 1109(b) of the Bankruptcy Code, and Federal Rule of Bankruptcy Procedure 9010(b); and such counsel hereby requests, pursuant, inter alia, to Federal Rules of Bankruptcy Procedure 2002, 3017 and 9007 and 342 and 1109(b) of the Bankruptcy Code, that copies of all notices and pleadings given or filed in this case be given to and served upon the undersigned at the following address and telephone number: Zachary Bancroft, Esq. Lowndes, Drosdick, Doster, Kantor & Reed, P.A. 450 South Orange Avenue, Suite 800 Orlando, Florida 32801 Tel: 407.843-4600 Fax: 407.843-4444 Email: [email protected]

CASE NO: 10-13800-SCC


JOINTLY ADMINISTERED

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Further, the undersigned consents to service of papers and notices via electronic mail, facsimile, or other electronic means at the telecopier or electronic mail address shown above. PLEASE TAKE FURTHER notice that, pursuant to 1109(b) of the Bankruptcy Code, the foregoing demand includes not only the notices and papers referred to in the rules specified above but also includes, without limitation, any notice, application, complaint, demand, motion, petition, pleading or request, whether formal or informal, written or oral and whether transmitted or conveyed by mail, delivery, telephone, telegraph, telex, facsimile, or otherwise filed or made in or with regard to the referenced case and proceedings herein. This Notice of Appearance of Request for Service of Notices and Papers shall not be deemed or construed to be a waiver of Anands rights (1) to have final orders in noncore matters entered only after de novo review by a District Judge, (2) to trial by jury in any proceeding so triable in this case, controversy, or proceedings related to this case, or (3) to have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal. /s/ Zachary J. Bancroft Zachary Bancroft, Esq. Florida Bar No. 0145068 L. William Porter III Florida Bar No. 0116882 Lowndes, Drosdick, Doster, Kantor & Reed, P.A. 450 South Orange Avenue, Suite 800 Orlando, Florida 32801 Tel: 407.843-4600 Fax: 407.843-4444 Email: [email protected] Attorneys for Anand Enterprise, Inc.

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CERTIFICATE OF SERVICE I HEREBY CERTIFY, that on this 28th day of October, 2010, to the extent that the foregoing NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF NOTICES AND PAPERS was not served electronically via the CM/ECF System, I caused a copy of the NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF NOTICES AND PAPERS to be served via first class mail postage prepaid, to the persons on the attached Service List. /s/ Zachary J. Bancroft Zachary Bancroft, Esq. SERVICE LIST Innkeepers USA Trust 340 Royal Poinciana Way, Suite 306 Palm Beach, FL 33480 Jennifer Marines Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Patrick M. Bryan Kirkland and Ellis, LLP 655 Fifteenth Street N.W. Washington, DC 20005 Paul M. Basta Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 U.S. Trustee United States Trustee 33 Whitehall Street 21st Floor New York, NY 10004 Paul Kenan Schwartzberg Office of the United States Trustee 33 Whitehall Street 21st Floor New York, NY 10004 Brett H. Miller Lorenzo Marinuzzi Morrison & Foerster LLP 1290 Avenue of the Americas New York, NY 10104

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