1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Michael G. Helms 014470 THE HELMS LAW FIRM, P.L.C. 2600 North Central Avenue, Suite 940 Phoenix, Arizona 85004 Telephone: (602) 358-2060 Fax: (602) 358-2055 mghelms@mghlawfirm.com Attorneys for Best Western International, Inc. IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al. Debtors. Case No. 10-13800 (SCC) Chapter 11

MOTION OF MICHAEL G. HELMS FOR ADMISSION PRO HAC VICE 1. The undersigned hereby moves this Court for an order admitting Michael

G. Helms to appear and participate in the above entitled case Pro Hac Vice on behalf of Best Western International, Inc., by whom I have been retained: 2. I am an attorney with the following law firm: The Helms Law Firm, P.L.C. 2600 North Central Avenue, Suite 940 Phoenix, Arizona 85004 3. I am a member of the Bar of the State of Arizona, and in good standing and

21

eligible to practice before the following courts:

22 23 24 25 26

Arizona Nebraska (inactive) United States District Court for the District of Nebraska United States District Court for the District of Arizona United States District Court for the Central District of Illinois

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

United States Court of Appeals for the Eighth Circuit United States Court of Appeals for the Ninth Circuit United States Court of Appeals for the Fourth Circuit United States Supreme Court 4. I have not been disciplined by any court or administrative body, nor are

there any disciplinary proceedings or criminal proceedings pending against me. 5. I submit to the disciplinary jurisdiction of this Court for any alleged

misconduct which occurs in the course of my representation of Best Western International, Inc., pursuant to Rule 2090-1(b) of the Local Rules of the United States Bankruptcy Court for the Southern District of New York. 6. I have access to, or have acquired, a copy of the Local Rules of this Court,

am generally familiar with such Rules, and will comply with such Rules. 7. I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct.

Dated this 30th day of July, 2010. THE HELMS LAW FIRM, P.L.C.

By: /s/ Michael G. Helms Michael G. Helms 2600 North Central Avenue Suite 940 Phoenix, Arizona 85004 Telephone: (602) 358-2060 Attorney for Best Western International, Inc.

1 2 3 4 5 6 7 8 9 10 11 12 13 14

IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al. Debtors. Case No. 10-13800 (SCC) Chapter 11

ORDER Upon the Motion for Admission pro hac vice submitted herein by Michael G. Helms, to represent Best Western International, Inc., in this case; and upon consideration of the motion, IT IS ORDERED granting said application. Michael G. Helms is admitted pro hac vice to represent Best Western International, Inc., in the above-captioned case and may appear in this case and any related proceedings.

15 16 17 18 19 20

Dated: August , 2010 New York, New York

BY THE COURT:

United States Bankruptcy Judge

21 22 23 24 25 26