UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

)
In re: ) Chapter 11
) Case No. 10-13800
Innkeepers USA Trust, eta/., ) Jointly Administered
)
)
Debtors.)
)
Page 1 of 8
07/13/2011
Page 2 of 8
The Honorable Judge Shelley C. Chapman:
After reading June 29, 2001 Press Release it states on June 24, 2011 that you" intend to
sign off on the hotel companies restructuring." "The plan has the support of Innkeepers secure
creditors and more than 90% of its unsecured creditors, according to a company statement."
The question I have was the vote that I had to send in to be there June 17, 2011 to be
counted on. Was that a legal vote?
The reason I asked this was that ( I voted for restructuring ) and June 22, 2011 the day
before the Confirmation Hearing: I received in the mail where some debtors have filed the
OMNIBUS objection ( each a "disputed claim" ) This is the ninth OMNIBUS objections to
claims. This is the first time I got a noticed of the objection.
1) Here is a envelope dated on May 21, 2011. The letter was a ballot enclosed. Stating that I
was getting the money.
2) Here is an envelope dated June 15,2011 stating "disallow and expunge." "The basis for
objection" "equity interest." My claim was not for holding equity it was for the
payment of dividends.
3) The ninth OMNIBUS objection to claims are: ( claims to be reclassified, claims to be
adjusted, compound claims to be reclassified, wrong debtor claims to be reclassified, no liability
claims, wrong debtor claims, equity claims, insufficient support claims, amended and replaced
claims, and duplicative claims.)
4) You can note my claim was not for reclassified. My claim was for dividends. To me it
should be reclassified to be dividends.
5) With these ten objection to claims above (in #3) how come in the news Press release that
90 percent that unsecured creditors support the plan according to a company statement. Is this
another Apollo inappropriately using the freedom of the press.
Date 7/t'J /I (

7J.Sl U.'S. H-<i"'v..>"CJ /I
Po-f.:skw..
NY- r3t;; 7
Page 3 of 8
MOTION OF Gareth Tooly FOR ALLOWANCE OF Claim# 1775 for $5,700.00 For
Dividends owed:
Reclassified to be dividends
, hereby files
its Motion for Allowance of $5, 700.00 of dividends owe for 3, 600 shares of Innkeepers
preferred C stock That I filed on 31912011 claim # 1775
2600 shares $0.50 per quarter. 4 Quarters equal $2.00 a share equal$ 5200.00
1000 shares $0.50 a quarter. 1 quarter equal $500.00
+
Total owed $5700.00
is here by ordered and sign
Date. _____ _ Sign. ________ _
Innkeepers Judge Approves Bankruptcy Plan, Sales to Cerberus and Chatham - Bloomberg
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Innkeepers Judge Approves Bankruptcy
Plan, Sales to Cerberus and Chatham
Q
By Tiffany Kmy-Jun 29,2011 5:22PM ET
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Innkeepers USA Trust won final court approval for a reorganization
plan that includes a sale of 64 of the company's hotels to Cerberus
CapHal Management LP and Chatham Lodging Trust (CLOT), paving
Hs way to exit bankruptcy.
U.S. Bankruptcy Judge Shelley Chapman approved the plan today,
after saying in Manhattan court June 24 that she intended to sign off
on the hotel company's restructuring. The plan has the support of
Innkeeper's secured creditors and more than 90 percent of its
unsecured creditors, according to a company statement.
"The successful restructuring of this company and the preservation of 3,500 jobs is a truly
remarkable achievement," given the hospHaiHy industry's challenges in 2010, said
Innkeepers' Chief Restructuring Officer, Marc A. Beilinson, in a statement.
Innkeepers owns 71 hotels in 20 U.S. states, induding Residence Inns by Marriott and
Hampton tnns. Lehman Ali, a unit of Lehman Brothers Holdings Inc. (LEHMQ), helped
finance the buyout of Innkeepers with a $1.2 billion loan. The company's bankruptcy petition
listed assets of $1.5 billion against debt totaling $1.52 billion.
The deaf returns Chatham Chief Executive Officer Jeffrey Fisher to Innkeepers, which he
founded in 1994 with seven hotels. The company was acquired by Apollo Investment Corp.
(AINV) in 2007.
Winning Bid
At an auction in May, Cerberus and Chatham placed a winning bid of $1.1 billion for the
largest group of hotels, topping an offer from Lehman Ali and Five Mile Capital Partners.
Chatham, a real estate investment trust based in Palm Beach, Florida, has 10 percent of the
joint venture formed with Cerberus, Fisher said.
In addition to the 64 hotels, Chatham won another group of five hotels with a bid of $195
million. Two other hotels will be turned over to lenders, according to court papers. Most of
Innkeepers' hotel portfolio is made up of extended-stay hotels, according to court papers.
Midland loan Services, the special servicer of an $825 million mortgage loan, and Lehman
filed objections to Innkeepers' bankruptcy plan and later withdrew them under an agreement
announced in court.
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--'"" -;J.
INNKEEPERS USA TRUST, et al.
c/o Omni Management Group, LLC.
16161 Ventura-Blvd., Suite C, PMB 606
Encino, CA 91436'-2522
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021M $()1.28
0008004922 1VAY2i
MAILED FROM ZIP CODE 8' 436
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Creditor:GARETII TOOL Y
Amount:$5,700.00
CaseNo: 10-13800
Debtor: InnkeeperS USA
Trust, et al.
Your rights are described in the Disclosure Statement. The Disclosure Statement, the
Plan, the Disclosure Statement Order, and certain other materials contained in the Solicitation
Package are included among the materials you are receiving with this Ballot. Additionally, the
Solicitation Package can be obtained (a) from the Debtors' Notice and Claims Agent by:
(i) visiting http://www.omnimgt.com/innkeepers; (ii) writing to Innkeepers USA Trust c/o Omni
Management Group, LLC, 16161 Ventura Boulevard, Suite C, PMB 606, Encino, California,
91436, or (iii) calling (866) 989-6147; or (b) for a fee via PACER (except for Ballots) at
http://www.nysb.uscourts.gov.
The Court has approved the Disclosure Statement as containing adequate information as
required under section 1125 of the Bankruptcy Code. Court approval of the Disclosure
Statement does not indicate approval of the Plan by the Court. This Ballot may not be used for
any purpose other than to vote to accept or reject the Remaining Debtor Plan. If you believe you
have received this Ballot in error, please contact the Notice and Claims Agent at the address or
telephone number set forth above.
You should review the Disclosure Statement and the Plan before you vote. You may wish
to seek legal advice concerning the Plan and the Plan's classification and treatment of your
Claim or Interest. Your Claim or Interest has been placed in Class R4A General Unsecured
Claims against the Remaining Debtors Other than Grand Prix Holdings under the Remaining
Debtor Plan. Jf you hold Claims or Interests in more than one Class, you will receive a Ballot
for each Class in which you are entitled to vote.
If the Notice and Claims Agent does not receive your Ballot on or before the Voting
Deadline, which is June 17, 2011, at 5:00 p.m. prevailing Eastern Time, and if the Voting
Deadline is not extended, at the Debtors' sole discretion, your vote as either an acceptance
or rejection of the Remaining Debtor Plan will not count.
Jf the Court confirms the Plan, it will bind you regardless of whether you vote.
Item 1. Principal Amount of Class R4A General Unsecured Claims against the Remaining
Debtors Other than Grand Prix Holdings.
The undersigned hereby certifies that as of the Voting Record Date, May 13, 2011, the
undersigned was the Holder of a Class R4A Claim against the Debtors in the following amount
(insert amount in box below):
$5.700.00
and the Form of Certain Documents To Be Distributed in Connection with Solicitation of the Plan; and
(D)Proposed Voting and General Tabulation Procedure (the "Disclosure Statement Order").
NID-909-26-C-1175
K&B 18696153.5
2
Innkeepers USA Trust, et al.
c/o Omni Management Group, LLC.
16161 Ventura Blvd., Suite C, PMB 606
Encino, CA 91436-2522
...,
PLEASE FORWARD TO PRESIDENT, LEGAL DEPAIUMENT, OR ADDRESSEE.

""'
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";:) PITIIIEY BOWES
02 1M $ 02.68
0008004922 JUN15 2011
MAILED FROM ZIP CODE 91436
-I;)
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PLEASE TAKE FURTHER NOTICE of the following important information
regarding the Omnibus Objection:
By the Omnibus Objection, the Debtors are seeking to disallow, expunge, reclassify,
and/or reduce your Claim(s) listed in the table below.
USA Trust,
et al.
Objection Procedures. On March 29, 2011, the United States Bankruptcy Court for the
Southern District of New York (the "Court'') entered an order [Docket No. 1 064] approving
procedures for filing and resolving objections to Claims asserted against the Debtors in the
Chapter 11 Cases (the "Objection Procedures"). Review the Objection Procedures to ensure
your response to the Omnibus Objection, if any, is timely and and served. <
Resolving Objections. To fi . . bjections,
certain of the Debtors' .wi!Hleiivaflable to discuss and potentially resOI . us
Objections to ut rums without the need for filing a formal response or attending a
o a 1tate such a discussion, please contact Jonathan Zinman at Kirkland & Ellis
ebtors' restructuring counsel) by (i) emailing jonathan.zinman@kirkland.com or
c mg (212) 446-4852 within 21 calendar days after the date of this Objection Notice.
e have your proof(s) of Claim and any related material available for any such discussions
all legal matters will be referred to the Debtors' counsel.
uired to File a are not able to resolve consensually the
Omnibus Objection filed with respect to your proof of claim before the deadline to respond to the
Onmibus Objection, you must file a response (each, a "Response") with the Court in accordance
with the procedures described below to contest the relief sought in the Omnibus Objection.
ABSENT REACHING AN AGREEMENT WITH THE DEBTORS RESOLVING THE
OMNIBUS OBJECTION TO A CLAIM, FAILURE TO FILE AND SERVE TIMELY A
RESPONSE AS SET FORTH HEREIN OR TO ATTEND THE HEARING SCHEDULED FOR
THE OMNIBUS OBJECTION TO A CLAIMANT'S CLAIMS MAY RESULT IN THE
COURT GRANTING THE OMNIBUS OBJECTION WITH RESPECT TO SUCH CLAIM
WITHOUT FURTHER NOTICE OR HEARING.
Response Contents. Each Response must contain the following (at a minimum):
a. a caption stating the nrune of the Court, the name of the Debtors, the case
number, and the Omnibus Objection to which the Response is directed;
b. a concise statement setting forth the reasons why the Court should not
grant the Onmibus Objection wi.ll:I respect to such proof of claim,
3 Asserted claim amounts listed as $0.00 reflect that the claim amount asserted is unliquidated.