DUANE MORRIS, LLP

1540 Broadway
ORIGINAL
14th Floor
New York, New York I 0036-4086
Telephone: (212) 692-1000
Facsimile: (212) 692-1020
William C. Heuer
Attorney for LNR Partners, LLC
UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------- )(
In re: Chapter 11
INNKEEPERS USA TRUST, et al., Case No. 10-13800 (SCC)
Debtors. Jointly Administered
)(
MOTION OF WILLIAM C. HEUER FOR
ADMISSION PRO HAC VICE OF MARGERY N. REED
William C. Heuer ("Movant"), a member in good standing of the Bar of the State of New
York, an attorney admitted to practice before the United States District Court for the Southern
District ofNew York, and associated with Duane Morris, LLP ("Duane Morris"), hereby moves
(the "Motion") this Court for an order admitting Margery N. Reed (the "Proposed Admittee")
pro hac vice to represent LNR Partners, LLC, in this case pursuant to Rule 2090-1 (b) of the
Local Rules of the United States Bankruptcy Court for the Southern District of New York (the
c
"Local Rules"). In support of this Motion, Movant relies upon the certification of the Pirodetl
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U) 2;: l">
Admittee which is attached as an e)(hibit hereto and respectfully represents as -
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1. LNR Partners, LLC would like Margery N. Reed, Esquire represent
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the above-captioned case. ' iSS ro
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2. Ms. Reed (mreed@duanemorris.com) is a partner of Duane Morris LLP ("Dulllie
Morris") and is based out of Duane Morris's Philadelphia, Pennsylvania office, which is located
at 30 S. 17th Street, Philadelphia, P A 19103-4196.
DMI\2268443.2
3. Ms. Reed is a member in good standing of Bars of the State of New Jersey and the
Commonwealth of Pennsylvania.
4. No disciplinary proceedings are currently pending against Ms. Reed and no
disciplinary action has previously been imposed upon her.
5. The Affidavit of Ms. Reed in support of this Motion is attached hereto as Exhibit
"A."
6. Ms. Reed acknowledges that she has reviewed and is familiar with the Local
Bankruptcy Rules for this Court.
7. Ms. Reed understands that if she is admitted pro hac vice, she will be subject to
the disciplinary jurisdiction of this Court.
WHEREFORE, I, William C. Heuer, respectfully request that this Court admit Margery
N. Reed, Esquire, pro hac vice, to serve as counsel for LNR Partners, LLC in the above-
captioned case and grant such further relief as may be necessary or appropriate.
July 26, 2010
DMI\2268443.2
Respectfully submitted,
DUANE MORRIS LLP
s/William C. Heuer U0, lk_ 0 ~
William C. Heuer
1540 Broadway
New York, NY 10036-4086
Telephone: (212) 692-1000
Facsimile: (212) 692-1020
E-mail: wheuer@duanemorris.com
Attorney for LNR Partners, LLC
DUANE MORRIS, LLP
1540 Broadway
14
1
h Floor
New York, New York 10036-4086
Telephone: (212) 692-1000
Facsimile: (212) 692-1020
William C. Heuer
Attorney for LNR Partners, LLC
UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------- X
In re: Chapter 11
INNKEEPERS USA TRUST, et al., Case No. 10-13800 (SCC)
Debtors. Jointly Administered
X
VERIFIED APPLICATION TO PRACTICE IN THIS COURT PURSUANT TO
LOCAL BANKRUPTCY RULE 2090-l(c)
I, Margery N. Reed, hereby apply for admission to practice in this Court pursuant to
Local Bankruptcy Rule 2090-1 (c) and, in support hereof, being of full age, depose and say:
1. I am a partner of Duane Morris LLP ("Duane Morris").
2. I am based out of Duane Morris's based out of Duane Morris's Philadelphia,
Pennsylvania office, which is located at 30 S. 17'h Street, Philadelphia, PA 19103-4196 ..
3. I am a member in good standing of the Bars of the State of New Jersey and the
Commonwealth of Pennsylvania.
4. I am not under any suspension or disbarment of any court.
5. No disciplinary proceedings are currently pending against me and no disciplinary
action has previously been imposed upon me.
6. I understand that ifl am admitted pro hac vice, I will be subject to the disciplinary
jurisdiction of this Court.
7. I have reviewed and am familiar with the Local Bankruptcy Rules for this Court.
DMI\2268443.2
8. I certify that the foregoing statements made by me are true. I am aware that, if
any of the foregoing statements made by me are willfully false, I am subject to punishment.
s/Margery N. Reed
Margery N. Reed
DMI\2268443.2
DUANE MORRIS, LLP
1540 Broadway
14th Floor
New York, New York I 0036-4086
Telephone: (212) 692-1000
Facsimile: (212) 692-1 020
William C. Heuer
Attorney for LNR Partners, LLC
UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------- )(
In re: Chapter II
INNKEEPERS USA TRUST, et al., Case No. 10-13800 (SCC)
Debtors. Jointly Administered
)(
CERTIFICATE OF SERVICE
I, William C. Heuer, a partner with the law firm of Duane Morris LLP, hereby certify on this 26th
day of July, 2010, I caused a true and correct copy of the foregoing Motion for Admission of
Margery N. Reed, Esquire Pro Hac Vice to be served upon the persons named below via first
class U.S mail, postage prepaid:
DMl\2268443.2
Paul M. Basta
Kirkland & Ellis, LLP
60 I Le)(ington A venue
New York, NY I 0022
Telephone: (212) 446-4800
Fa)( : (212) 446-4900
Lenard M. Parkins
Hayens and Boone, LLP
1221 Avenue of the Americas
26th Floor
New York, NY I 0020
Telephone: (212) 659-7300
Fa)(; (212) 918-8989
U.S. Trustee
United States Trustee
3 3 Whitehall Street
21st Floor
New York, NY 10004
Telephone: (212) 510-0500
Claims and Noticing Agent
Omni Mgmt. Group LLC Claims Agent
1650 I Ventura Blvd., Suite 440
Encino, CA 91436-2068
(818) 906-8300
Claims and Noticing Agent
Omni Management Group, LLC
16501 Ventura Blvd.
Suite 440
Encino, CA 91436-2068
(818) 906-8300
Under penalty of perjury, I declare that the foregoing is true and correct.
July 26, 20 I 0
DMI\2268443.2
DUANE MORRIS LLP
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William C. Heuer
DUANE MORRIS, LLP
1540 Broadway
14
1
h Floor
New York, New York I 0036-4086
Telephone: (212) 692-1000
Facsimile: (212) 692-1020
wheuer@duanemorris.com
Attorney for LNR Partners, LLC