United States Bankruptcy Court Southern District of New York

Hearing Date: May 24, 2011 at 11:00 a.m. (ET) Response Deadline: May 17, 2011 at 4:00 p.m.
(ET)
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession 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
NOTICE OF HEARING ON DEBTORS THIRD OMNIBUS OBJECTION TO CLAIMS (CHARTIS CLAIMS) PLEASE TAKE NOTICE that a hearing (the Hearing)2 for the relief requested in the above-referenced objection (the Objection) will be held, to the extent timely responses to the
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.
K&E 18761838.9
Objection are filed or a Hearing is otherwise deemed necessary, before the Honorable Shelley C. Chapman, United States Bankruptcy Judge, in Courtroom No. 610 of the United States Bankruptcy Court for the Southern District of New York (the Court), Alexander Hamilton Custom House, One Bowling Green, New York, New York 10004-1408, on May 24, 2011 at 11:00 a.m. prevailing Eastern Time or such other time as counsel may be heard. PLEASE TAKE FURTHER NOTICE that any responses to the Objection: (a) must be in writing; (b) shall conform to the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), all General Orders of the Court, the Local Rules for the United States Bankruptcy Court for the Southern District of New York, and the Notice, Case Management, and Administrative Procedures [Docket No. 68] (the Case Management Procedures) approved by the Court; (c) shall be filed with the Bankruptcy Court electronically by registered users of the Bankruptcy Courts case filing system (the Users Manual for the Electronic Case Filing System can be found at www.nysb.uscourts.gov, the official website for the Bankruptcy Court); and (d) shall be served so as to be actually received no later than May 17, 2011 at 4:00 p.m. prevailing Eastern Time by the entities on the Master Service List (as such term is defined in the Case Management Procedures), which is available at www.omnimgt.com/innkeepers, the website maintained by Omni Management Group, LLC, the Debtors notice and claims agent. Only those responses that are timely filed, served, and received will be considered.
All capitalized terms used but otherwise not defined herein shall have the meanings set forth in the Objection.
New York, New York Dated: April 19, 2011
/s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession
Hearing Date: May 24, 2011 at 11:00 a.m. (ET) Response Deadline: May 17, 2011 at 4:00 p.m. (ET)
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession 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
DEBTORS THIRD OMNIBUS OBJECTION TO CLAIMS (CHARTIS CLAIMS) Innkeepers USA Trust and certain of its affiliates, as debtors and debtors in possession (collectively, the Debtors), object (this Objection) to certain proofs of Claim (as defined
1
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.
below) filed by Chartis Specialty Insurance Company and certain of its affiliates (collectively, Chartis) listed on Schedule 1 to Exhibit A attached hereto (the Chartis Claims) and seek entry of an order, substantially in the form attached hereto as Exhibit A, disallowing and expunging the Chartis Claims, pursuant to section 502(b) of title 11 of the United States Code (the Bankruptcy Code) and Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules). In support of this Objection, the Debtors rely on the Declaration of Todd Brents in Support of Debtors Third Omnibus Objection to Claims (Chartis Claims) (the Brents Declaration), filed contemporaneously herewith. In further support of this Objection, the Debtors respectfully state as follows: Jurisdiction 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334. This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). 2. 3. Venue is proper in this Court pursuant to 28 U.S.C. 1408 and 1409. The bases for the relief requested herein are sections 105(a) and 502(b) of the
Bankruptcy Code and Bankruptcy Rule 3007. Relief Requested 4. By this Objection and pursuant to section 502 of the Bankruptcy Code and
Bankruptcy Rule 3007, the Debtors request that the Court enter an order disallowing and expunging the Chartis Claims against each of the Debtors identified on Schedule 1 to Exhibit A. Background 5. On July 19, 2010 (the Petition Date), each of the Debtors filed a petition with
the Court under chapter 11 of the Bankruptcy Code (collectively, the Chapter 11 Cases). The Chapter 11 Cases have been consolidated for procedural purposes only and are being jointly administered pursuant to Bankruptcy Rule 1015(b). The Debtors are operating their business and 2
managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No request for the appointment of a trustee has been made in the Chapter 11 Cases. On July 28, 2010, the United States Trustee for the Southern District of New York (the U.S. Trustee) appointed an official committee of unsecured creditors (the Creditors Committee). 6. Additional information regarding the Debtors business, capital structure, and the
circumstances leading to the Chapter 11 Cases is contained in the Amended Declaration of Dennis Craven, Chief Financial Officer of Innkeepers USA Trust, in Support of First Day Pleadings [Docket No. 33, as supplemented by Docket No. 516]. Claims Reconciliation Process 7. On or around September 1, 2010, the Debtors filed their statements of financial
affairs and schedules of assets and liabilities, current income and expenditures, and executory contracts and unexpired leases as required by section 521 of the Bankruptcy Code (collectively, the Exhibits). 8. On September 16, 2010, the Court entered an order (the Bar Date Order)
[Docket No. 440] establishing certain dates and deadlines for filing proofs of claim in the Chapter 11 Cases. Specifically, among other things, the Court established: (a) October 29, 2010 (the General Bar Date), as the deadline for all persons and entities holding or wishing to assert a claim (as defined in section 101(5) of the Bankruptcy Code) against any of the Debtors that arose prior to the Petition Date (each, a Claim), including any Claim arising under section 503(b)(9) of the Bankruptcy Code, to file proof of such Claim in writing; and (b) January 18, 2011 (the Governmental Bar Date), as the deadline for all governmental units holding or wishing to assert a Claim against any of the Debtors that arose prior to the Petition Date to file proof of such Claim in writing. 3
9.
On March 29, 2011, the Court entered an order approving omnibus Claims
objection procedures in the Chapter 11 Cases [Docket No. 1064] (the Claim Objection Procedures Order). 10. To date, entities have filed nearly 2,000 proofs of Claim against the Debtors on an
aggregate basis, pursuant to which such entities assert more than $6.75 billion in aggregate liabilities. Objection 11. The Debtors object to the 94 Chartis Claims on the ground they have no basis in
the Debtors books and records. Chartis provided on a prepetition basis (and continues to provide) the Debtors with a number of forms of insurance coverage, including, among others, excess directors and officers liability, property liability, automobile liability, and general liability.3 Chartis filed 94 identical proofs of Claim against certain of the Debtors in the Chapter 11 Caseseach asserting Claims in the amount of $3,108,000 for what Chartis alleges are pastdue amounts owed under certain of the Debtors insurance policies. 12. Notwithstanding these alleged Claims, the Debtors are current on their payments
to Chartis. As part of the Debtors first-day relief, the Court entered an order authorizing the Debtors to pay all prepetition obligations with respect to insurance policies [Docket No. 186] (the Insurance Order). And on December 14 and 20, 2010, the Court entered orders allowing the Debtors to enter into new insurance premium financing agreements to ensure the Debtors are able to continue paying their insurance premiums on a timely basis [Docket Nos. 759, 772]. Under the authority of this relief, the Debtors have remained current on their payments to Chartis
Further details on the Debtors insurance coverage is available in the Debtors' Motion for the Entry of an Order Authorizing, but not Directing, the Debtors to (A) Maintain Prepetition Insurance Policies and Premium Financing Agreements and (B) Pay All Prepetition Obligations in Respect Thereof [Docket No. 17].
and their books and records indicate they owe no liability on account of the Chartis Claims. The Debtors therefore object to all of the Chartis Claims. Basis for Relief 13. A filed proof of claim is deemed allowed unless a party in interest objects thereto.
See 11 U.S.C. 502(a); see also id. 1111(a) (A proof of claim . . . is deemed filed under section 501 of this title for any claim . . . that appears in the schedules . . . except a claim . . . that is scheduled as disputed, contingent, or unliquidated.). If an objection refuting at least one of the claims essential allegations is asserted, the claimant has the burden to demonstrate validity of the claim. See, e.g., Sherman v. Novak (In re Reilly), 245 B.R. 768, 773 (2d Cir. BAP 2000); In re Rockefeller Ctr. Props., 272 B.R. 524, 539 (Bankr. S.D.N.Y. 2000); In re St. Johnsbury Trucking Co., 206 B.R. 318. 323 (Bankr. S.D.N.Y. 1997). 14. As described in the Brents Declaration, neither the Debtors books and records
nor the supporting documentation filed by Chartis with its Claims indicate that Chartis has a Claim against the Debtors. As such, the Debtors respectfully submit that all of the Chartis Claims should be expunged and disallowed in their entirety. Elimination of these Claims will ensure that Chartis does not receive an unwarranted recovery against the Debtors to the detriment of the Debtors estates. 15. For the reasons stated above, the Debtors object to the Chartis Claims and
respectfully request this Court enter an order disallowing and expunging the Chartis Claims. Motion Practice 16. This Objection includes citations to the applicable rules and statutory authorities
upon which the relief requested herein is predicated and a discussion of their application to this Objection. Accordingly, the Debtors submit that this Objection satisfies Rule 9013-1(a) of the Local Rules of Bankruptcy Procedure for the Southern District of New York. 5
Reservation of Rights 17. This Objection is limited to the grounds stated herein. Accordingly, it is without
prejudice to the rights of the Debtors or any other party in interest to object to any of the Chartis Claims on any ground whatsoever and the Debtors expressly reserve all further substantive or procedural objections they may have. Notice 18. The Debtors have provided notice of this Motion to the entities on the Master
Service List (as such term is defined in the Notice, Case Management, and Administrative Procedures [Docket No. 68]), which is available at www.omnimgt.com/innkeepers, the website maintained by Omni Management Group, LLC, the Debtors notice and claims agent. The Debtors respectfully submit that no further notice is necessary.
WHEREFORE, the Debtors respectfully request that the Court grant the relief requested in the Objection and such other relief as the Court deems just and proper. New York, New York Dated: April 19, 2011 /s/ Brian S. Lennon James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 Counsel to the Debtors and Debtors in Possession
Exhibit A Proposed Order
James H.M. Sprayregen, P.C. Paul M. Basta Stephen E. Hessler Brian S. Lennon KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022-4611 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 and Anup Sathy, P.C. (admitted pro hac vice) Marc J. Carmel (admitted pro hac vice) KIRKLAND & ELLIS LLP 300 North LaSalle Street Chicago, Illinois 60654-3406 Telephone: (312) 862-2000 Facsimile: (312) 862-2200 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
ORDER GRANTING DEBTORS THIRD OMNIBUS OBJECTION TO CLAIMS (CHARTIS CLAIMS) Upon the Debtors Third Omnibus Objection to Claims (Chartis Claims) (the Objection)2 filed by Innkeepers USA Trust and certain of its affiliates, as debtors and debtors in possession (collectively, the Debtors) requesting entry of an order disallowing and
1
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. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Objection.
expunging the Chartis Claims listed on Schedule 1 attached hereto, pursuant to sections 105(a) and 502(b) of title 11 of the United States Code (the Bankruptcy Code) and Rule 3007 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules); all as more fully described in the Objection; it appearing that the relief requested is in the best interests of the Debtors estates, their creditors, and other parties in interest; the Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157(b); venue being proper before this court pursuant to 28 U.S.C. 1408 and 1409; notice of the Motion having been adequate and appropriate under the circumstances; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. 2. The Objection is granted to the extent set forth herein. The Chartis Claims listed in Schedule 1 attached hereto are hereby disallowed
and expunged in their entirety pursuant to section 502(b) of the Bankruptcy Code. 3. Omni Management Group, LLC, the Debtors notice and claims agent, is hereby
authorized to update the Claims register to reflect the relief granted in this Order. 4. The terms and conditions of this Order shall be immediately effective and
enforceable upon its entry. 5. All time periods set forth in this Order shall be calculated in accordance with
Bankruptcy Rule 9006(a). 6. The Debtors are authorized to take all actions necessary to effectuate the relief
granted pursuant to this Order in accordance with the Motion. 7. This Court retains jurisdiction with respect to all matters arising from or related to
the implementation of this Order.
New York, New York Dated: _________________, 2011
Honorable Shelley C. Chapman United States Bankruptcy Judge
Schedule 1 Chartis Claims
Third Omnibus Objection

Claim # Debtor Grand Prix San Jose LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
In re:Innkeepers USA Trust Case No 10-13800
Total $3,108,000.00
Claim To Be Disallowed Filed On:
1148 10/29/2010
Creditor:
CHARTIS U.S. ATTN: MICHELLE A. LEVITT 175 WATER STREET, 18TH FLOOR NEW YORK, NY 10038
1149 10/29/2010
Grand Prix Troy (SE) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1150 10/29/2010
Grand Prix Tukwila LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1155 10/29/2010
KPA RIGG, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 1

Claim # Debtor Grand Prix Troy (Central) LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1160 10/29/2010
Creditor:
CHARTIS U.S. ATTN: MICHELLE A. LEVITT 175 WATER STREET, 18TH FLOOR NEW YORK, Ny 10038
1165 10/29/2010
KPA HS Anaheim, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1171 10/29/2010
KPA Leaseco Holding, Inc.
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1177 10/29/2010
KPA Leaseco, Inc.
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 2

Claim # Debtor KPA/GP Valencia LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1188 10/29/2010
Creditor:
1198 10/29/2010
KPA RIMV, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1217 10/29/2010
KPA San Antonio, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1218 10/29/2010
KPA Tysons Corner RI, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 3

Claim # Debtor KPA Washington DC, LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1220 10/29/2010
Creditor:
1223 10/29/2010
KPA/GP Ft. Walton LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1226 10/29/2010
KPA/GP Louisville (HI) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1229 10/29/2010
KPA HI Ontario LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 4

Claim # Debtor Grand Prix Saddle River LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1233 10/29/2010
Creditor:
1253 10/29/2010
Innkeepers USA Trust, et al.
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1260 10/29/2010
Grand Prix Altamonte LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1265 10/29/2010
Grand Prix Albany LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 5

Claim # Debtor Grand Prix Addison (SS) LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1278 10/29/2010
Creditor:
1282 10/29/2010
Grand Prix Addison (RI) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1284 10/29/2010
GP AC Sublessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1285 10/29/2010
Grand Prix Term Lessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 6

Claim # Debtor Grand Prix Mezz Borrower Floating, LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1287 10/29/2010
Creditor:
1289 10/29/2010
Grand Prix Mezz Borrower Floating 2, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1290 10/29/2010
Grand Prix Naples LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1293 10/29/2010
Innkeepers USA Limited Partnership
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 7

Claim # Debtor Grand Prix Ontario Lessee, LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1294 10/29/2010
Creditor:
1296 10/29/2010
Grand Prix Ontario LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1297 10/29/2010
Grand Prix Holdings LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1298 10/29/2010
Grand Prix Las Colinas LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 8

Claim # Debtor Grand Prix Lexington LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1299 10/29/2010
Creditor:
1300 10/29/2010
Grand Prix Livonia LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1301 10/29/2010
Grand Prix Lombard LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1303 10/29/2010
Grand Prix Louisville (RI) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 9

Claim # Debtor Grand Prix Lynnwood LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1304 10/29/2010
Creditor:
1305 10/29/2010
Grand Prix Mezz Borrower Fixed, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1307 10/29/2010
Grand Prix Mezz Borrower Term LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1308 10/29/2010
Grand Prix Montvale LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 10

Claim # Debtor Grand Prix Morristown LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1310 10/29/2010
Creditor:
1311 10/29/2010
Grand Prix Mountain View LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1312 10/29/2010
Grand Prix Mt. Laurel LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1313 10/29/2010
Grand Prix Islandia LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 11

Claim # Debtor Grand Prix Fixed Lessee LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1314 10/29/2010
Creditor:
1316 10/29/2010
Grand Prix Ft. Lauderdale LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1317 10/29/2010
Grand Prix Fremont LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1318 10/29/2010
Grand Prix East Lansing LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 12

Claim # Debtor Grand Prix East Lansing LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1319 10/29/2010
Creditor:
1321 10/29/2010
Grand Prix Englewood / Denver South LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1322 10/29/2010
Grand Prix Atlantic City LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1323 10/29/2010
Grand Prix Bellevue LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 13

Claim # Debtor Grand Prix Belmont LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1325 10/29/2010
Creditor:
1326 10/29/2010
Grand Prix Binghamton LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1327 10/29/2010
Grand Prix Atlanta LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1328 10/29/2010
Grand Prix Atlanta (Peachtree Corners) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 14

Claim # Debtor Grand Prix Arlington LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1329 10/29/2010
Creditor:
1330 10/29/2010
Grand Prix Anaheim Orange Lessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1332 10/29/2010
Grand Prix Floating Lessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1333 10/29/2010
Grand Prix Ft. Wayne LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 15

Claim # Debtor Grand Prix Indianapolis LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1334 10/29/2010
Creditor:
1336 10/29/2010
Grand Prix Gaithersburg LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1337 10/29/2010
Grand Prix General Lessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1338 10/29/2010
Grand Prix Germantown LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 16

Claim # Debtor Grand Prix Grand Rapids LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1340 10/29/2010
Creditor:
1342 10/29/2010
Grand Prix Harrisburg LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1344 10/29/2010
Grand Prix Horsham LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1345 10/29/2010
Grand Prix IHM, Inc
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 17

Claim # Debtor Grand Prix Columbia LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1346 10/29/2010
Creditor:
1348 10/29/2010
Grand Prix Denver LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1349 10/29/2010
Grand Prix Binghamton LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1351 10/29/2010
Grand Prix Bulfinch LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 18

Claim # Debtor Grand Prix Campbell / San Jose LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1353 10/29/2010
Creditor:
1355 10/29/2010
Grand Prix Cherry Hill LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1356 10/29/2010
Grand Prix Chicago LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1358 10/29/2010
Grand Prix Rockville LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 19

Claim # Debtor Grand Prix Rockville LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1359 10/29/2010
Creditor:
1360 10/29/2010
Grand Prix RIMV Lessee, LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1362 10/29/2010
Grand Prix Sili I LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1364 10/29/2010
Grand Prix Sili II LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 20

Claim # Debtor Grand Prix Portland LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1366 10/29/2010
Creditor:
1367 10/29/2010
Grand Prix Richmond (Northwest) LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1368 10/29/2010
Grand Prix Richmond LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1369 10/29/2010
Grand Prix RIGG Lessee LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 21

Claim # Debtor Grand Prix RIGG Lessee LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1371 10/29/2010
Creditor:
1372 10/29/2010
Innkeepers Financial Corporation
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1374 10/29/2010
Grand Prix San Mateo LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1375 10/29/2010
Grand Prix Shelton LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 22

Claim # Debtor Grand Prix Schaumburg LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1376 10/29/2010
Creditor:
1378 10/29/2010
Grand Prix Westchester LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1380 10/29/2010
Grand Prix West Palm Beach LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
1381 10/29/2010
Grand Prix Willow Grove LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Page 23

Claim # Debtor Grand Prix Windsor LLC Name and Address of Claimant Secured $3,108,000.00 Administrative $0.00 Priority $0.00 Unsecured $0.00
Total $3,108,000.00
1383 10/29/2010
Creditor:
1384 10/29/2010
Grand Prix Woburn LLC
Creditor:
$3,108,000.00
$0.00
$0.00
$0.00
$3,108,000.00
Claims To Be Disallowed Totals
94
$292,152,000.00
$0.00
$0.00
$0.00
$292,152,000.00
Page 24

United States Bankruptcy Court Southern District of New York

Cargado por

Información del documento

Descripción original:

Título original

Derechos de autor

Formatos disponibles

Compartir este documento

Compartir o incrustar documentos

Opciones para compartir

¿Le pareció útil este documento?

¿Este contenido es inapropiado?

Copyright:

Formatos disponibles

United States Bankruptcy Court Southern District of New York

Cargado por

Copyright:

Formatos disponibles

Hearing Date: May 24, 2011 at 11:00 a.m. (ET) Response Deadline: May 17, 2011 at 4:00 p.m.

New York, New York Dated: April 19, 2011

Exhibit A Proposed Order

the implementation of this Order.

New York, New York Dated: _________________, 2011

Honorable Shelley C. Chapman United States Bankruptcy Judge

Schedule 1 Chartis Claims

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On:

Grand Prix Troy (SE) LLC

Claim To Be Disallowed Filed On:

Grand Prix Tukwila LLC

Claim To Be Disallowed Filed On:

KPA RIGG, LLC

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On:

KPA HS Anaheim, LLC

Claim To Be Disallowed Filed On:

KPA Leaseco Holding, Inc.

Claim To Be Disallowed Filed On:

KPA Leaseco, Inc.

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On:

KPA RIMV, LLC

Claim To Be Disallowed Filed On:

KPA San Antonio, LLC

Claim To Be Disallowed Filed On:

KPA Tysons Corner RI, LLC

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On:

KPA/GP Ft. Walton LLC

Claim To Be Disallowed Filed On:

KPA/GP Louisville (HI) LLC

Claim To Be Disallowed Filed On:

KPA HI Ontario LLC

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On:

Innkeepers USA Trust, et al.

Claim To Be Disallowed Filed On:

Grand Prix Altamonte LLC

Claim To Be Disallowed Filed On:

Grand Prix Albany LLC

Third Omnibus Objection

Schedule 1 Chartis Claims

In re:Innkeepers USA Trust Case No 10-13800

Claim To Be Disallowed Filed On:

Claim To Be Disallowed Filed On: