Attorneys For The Independent Committee

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10-13800-scc

Doc 2239

Filed 12/05/11 Entered 12/05/11 14:56:19 Pg 1 of 4

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Hearing Date: December 13, 2011 at 2:00 PM Eastern Standard Time Objection Deadline: December 6, 2011 at 4:00 PM Easter Standard Time

Brad Eric Scheler, Esq. Bonnie Steingart, Esq. FRIED, FRANK, HARRIS, SHRIVER & JACOBSON LLP One New York Plaza New York, New York 10004 Telephone: (212) 859-8000 Facsimile: (212) 859-4000 Attorneys for the Independent Committee 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

ADDENDUM TO FOURTH INTERIM AND FINAL FEE APPLICATION OF FRIED, FRANK, HARRIS, SHRIVER & JACOBSON LLP FOR COMPENSATION FOR SERVICES AND REIMBURSEMENT OF EXPENSES AS ATTORNEYS FOR THE INDEPENDENT COMMITTEE FOR THE PERIOD FROM JULY 19, 2010 THROUGH OCTOBER 31, 2011

This is an addendum to the Fourth Interim and Final Fee Application of Fried, Frank, Harris, Shriver & Jacobson (Fried Frank) for the Period from July 19, 2010 through October 31, 2011 [Docket No. 2230] (the Final Fee Application). Name of Applicant: Fried, Frank, Harris, Shriver & Jacobson LLP

Authorized to Provide Professional Services to: Committee of Independent Trustees of the Board of Trustees of Innkeepers USA Trust Date of Retention: Order entered on November 10, 2010 retaining Fried, Frank, Harris, Shriver & Jacobson LLP, nunc pro tunc to September 10, 2010

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.

10-13800-scc

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Period for which Compensation and Reimbursement Is Sought: July 19, 2010 through October 31, 2011 Amount of Compensation Sought as Actual, Reasonable, and Necessary: Amount of Expense Reimbursement Sought as Actual, Reasonable, and Necessary: $1,612,748.50 $49,404.21

PLEASE TAKE NOTICE THAT on November 22, 2011, Fried Frank filed the Final Fee Application. Subsequent to filing the Final Fee Application, on account of the Monthly Application of Fried Frank for Compensation of Services and Reimbursement of Expenses as Attorneys for the Independent Committee for the Period from September 1, 2011 Through September 30, 2011 [Docket No. 2191] (the Eleventh Monthly Application), Fried Frank received (a) payment of compensation in the amount of $12,590.00 (80% of $15,737.50 of fees) on account of actual and necessary professional services rendered to the Independent Committee by Fried Frank and (b) reimbursement of actual and necessary costs and expenses in the amount $92.54 (representing 100% of expenses). Fried Frank hereby files this addendum to the Final Fee Application to reflect the receipt of this payment.

10-13800-scc

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Summary of Prior Monthly Applications and Payments:


Date Filed 11/24/2010 12/23/2010 1/26/2011 3/15/2011 3/23/2011 4/29/2011 5/31/2011 6/30/2011 7/29/2011 9/30/2011 10/31/2011 TOTAL Period Covered 9/10/2010-10/31/2010 11/1/2010-11/30/2010 12/1/2010-12/31/2010 1/1/2011-1/31/2011 2/1/2011-2/28/2011 3/1/2011-3/31/2011 4/1/2011-4/30/2011 5/1/2011-5/31/2011 6/1/2011-6/30/2011 8/1/2011-8/31/2011 9/1/2011-9/30/2011 10/1/2011-10/31/20112 Requested Fees Expenses $243,259.00 $3,458.29 $85,206.00 $3,182.31 $137,010.50 $1,589.43 $234,653.50 $3,207.92 $385,770.50 $16,770.64 $305,500.00 $13,624.38 $62,593.50 $5,048.90 $107,900.50 $893.29 $31,995.00 $794.60 $9,884.50 $514.81 $15,737.50 $92.54 $10,556.00 $227.10 $1,627,748.503 $49,404.21 Paid Fees $243,259.00 $85,206.00 $137,010.50 $234,653.50 $385,770.50 $305,500.00 $62,593.50 $107,900.50 $31,995.00 $7,907.60 $12,590.00 $0.00 $1,599,386.10 Expenses $3,458.29 $3,182.31 $1,589.43 $3,207.92 $16,770.64 $13,624.38 $5,048.90 $893.29 $794.60 $514.81 $92.54 $0.00 $49,177.11

Summary of Any Objections to Monthly Applications: None Filed. Summary of Previously Filed Interim Applications:
Date Filed 1/14/2011 5/13/2011 9/14/2011 Period Covered 7/19/2010-11/30/2010 12/1/2010-3/31/2011 4/1/2011-7/31/2011 Requested Fees Expenses $328,465.00 $6,640.60 $1,062,934.50 $35,192.37 $202.489.00 $6,736.79 Amount Approved by Court Fees Expenses $313,465.00 $6,640.60 $850,347.60 $35,197.37 $202.489.00 $6,736.79

Fees and costs incurred by Fried Frank from October 1, 2011 through October 31, 2011 have not been previously submitted to the Court in a monthly fee application. As discussed in the Final Fee Application, Fried Frank's fees totaled $1,627,748.50 for the Compensation Period. Fried Frank agreed to reduce its fees by a total of $15,000 for the First Interim Fee Period. As such, Fried Frank is hereby requesting final allowance of $1,612,748.50.

10-13800-scc

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PLEASE TAKE FURTHER NOTICE that, pursuant to the Courts Order Authorizing the Establishment of Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and Official Committee Members, dated August 12, 2010 [Docket. No. 189] (the Interim Compensation Order), objections, if any, to the Final Fee Application must be filed with the Court and served on the Applicant at the address set forth below and the Notice Parties (as such term is defined in the Interim Compensation Order) so as to be actually received by 4:00 p.m. prevailing Eastern Time on December 6, 2011. A hearing is set regarding the Final Fee Application for 2:00 p.m. prevailing Eastern Time on December 13, 2011. Dated: New York, New York December 5, 2011 FRIED, FRANK, HARRIS, SHRIVER & JACOBSON LLP By: _ /s/ Bonnie Steingart ____ Bonnie Steingart

One New York Plaza New York, New York 10004 Telephone: 212.859.8000 Facsimile: 212.859.4000 Attorneys for the Independent Committee

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