You are on page 1of 25

US2008 2329951.

1
KILPATRICK TOWNSEND & STOCKTON LLP
Todd C. Meyers, Esq.
Rex R. Veal, Esq.
Mark A. Fink, Esq.
1100 Peachtree Street, Suite 2800
Atlanta, GA 30309-4530
Telephone: (404) 815-6500
Facsimile: (404) 541-6555

Michael D. Crisp, Esq.
31 West 52nd Street, 14th Floor
New York, NY 10019
Telephone: (212) 775-8703
Facsimile: (212) 775- 8819

Counsel for TriMont Real Estate Advisors, Inc.,
as Special Servicer

UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK


In re:
)
)

Chapter 11
)
INNKEEPERS USA TRUST, et al., ) Case No. 10-13800 (SCC)
)
Debtors. ) Jointly Administered
)

NOTICE OF FILING OF DECLARATION OF LEE EICHEN
SUBMITTED ON BEHALF OF TRIMONT REAL ESTATE ADVISORS, INC.


PLEASE TAKE NOTICE that TriMont Real Estate Advisors, Inc. (TriMont), as
special servicer for the benefit of SASCO 2008-C2, LLC, as 100% participant and owner of all
economic and beneficial interests in the loans described on Exhibit 1 (SASCO or the
Mezzanine Lender), hereby files the attached Declaration of Lee Eichen Submitted on Behalf
of TriMont Real Estate Advisors, Inc.


US2008 2329951.1

Dated: March 1, 2011 KILPATRICK TOWNSEND & STOCKTON LLP

By: /s/ Todd C. Meyers
Todd C. Meyers, Esq. (GA Bar No. 503756)
Rex R. Veal, Esq. (GA Bar No. 726607)
Mark A. Fink, Esq. (NY Bar No. MF 8665)
1100 Peachtree Street, Suite 2800
Atlanta, GA 30309-4530
Telephone: (404) 815-6500
Facsimile: (404) 541-6555

tmeyers@kilpatricktownsend.com
rveal@kilpatricktownsend.com
mfink@kilpatricktownsend.com

Michael D. Crisp, Esq.
31 West 52nd Street, 14th Floor
New York, NY 10019
Telephone: (212) 775-8703
Facsimile: (212) 775- 8819

mcrisp@ kilpatricktownsend.com

Counsel for TriMont Real Estate Advisors, Inc. as
Special Servicer
US2008 2329951.1
EXHIBIT 1

TriMont Real Estate Advisors, Inc. is the Special Servicer with respect to the mezzanine
loans identified below and is authorized to act on behalf of SASCO 2008-C2, LLC, the
owner of all of the economic and beneficial interests in such mezzanine loans.

1. Borrower: Grand Prix Mezz Borrower Term LLC
Guarantor: Grand Prix Holding, LLC
Operating Lessee: Grand Prix Anaheim Orange Lessee LLC
Date: June 29, 2007 (and as subsequently amended from time to time)
Original Principal Balance: $21,300,000.00
Unpaid Principal Balance as of the Petition Date: $21,300,000.00

2. Borrower: Grand Prix Mezz Borrower 2 Floating LLC
Guarantor: Grand Prix Holdings , LLC
Operating Lessee: Grand Prix Floating Lessee LLC
Date: June 29, 2007 (and as subsequently amended from time to time)
Original Principal Balance: $117,658,725.00
Unpaid Principal Balance as of the Petition Date: $112,223,846.00
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
In re:
INNKEEPERS USA TRUST, eta!.,
Debtors.
)
)
)
)
)
)
Chapter 11
Case No. 10-13800 (SCC)
Jointly Administered
_________________________ )
DECLARATION OF LEE EICHEN SUBMITTED ON BEHALF
OF TRIMONT REAL ESTATE ADVISORS, INC.
Lee Eichen, being first duly sworn, deposes and says of his own personal knowledge as
follows:
1. I am over the age of 18 and am competent to testify.
2. I am a citizen and resident ofthe State ofNew York.
3. I am presently employed as Managing Director and Founding Partner of
Centerboard Group, LLC ("Centerboard"), a boutique financial advisory firm located at 140
West 57th Street, 11th Floor, New York, NY 10019. The facts set forth in this Declaration are
based upon my personal knowledge. If called and sworn as a witness, I could and would testify
competently to the matters set forth herein.
4. I submit this declaration (this "Declaration") in accordance with Rule 1007-2 of
the Local Bankruptcy Rules for the Southern District of New York (the "Local Bankruptcy
Rules") in opposition to the Motion for Entry of an Order (I) Authorizing the Debtors to Enter
into the Commitment Letter with Five Mile Capital II Pooling REIT LLC, Lehman ALI Inc., and
Midland Loan Services, (II) Approving the New Party/Midland Commitment Between the
Debtors and Midland Loan Services, (III) Approving Bidding Procedures, (IV) Approving Bid
Protections, (V) Authorizing an Expense Reimbursement To "Bidder D, "and (VI) ModifYing
Cash Collateral Order to Increase Expense Reserve (the "Motion").
5. I was retained by TriMont Real Estate Advisors, Inc. to evaluate the proposed
business transactions underlying the Motion. I and others at Centerboard under my direction and
control performed an evaluation and analysis of those transactions and I prepared a written report
containing certain of my opinions and conclusions concerning those business transactions and
providing the basis for my opinions and conclusions (the "Eichen Expert Report"). A true and
correct copy of the Eichen Expert Report which bears my signature is attached to this
Declaration as Exhibit A. If called and sworn as a witness, I could and would testify
competently to the matters set forth in Exhibit A.
Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true
and correct. .f
/J
This the 'f&___ day 2011.
SWORN TO AND W,BSCRIBED
before me this tlay
of rebf<v/JIZy , 2011.

Notary Public
My Commission Expires:
1-:1:7-- IS
ALBERTO J. GARCIA
Notary Publi9, State of New York
No. 01GA6053013
in New York County
CommiSSIOn Expires January 29, 20-'fi:
US2008 2329951.1
EXHIBIT A

EICHEN EXPERT REPORT
- 1 -

UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK


In re:

INNKEEPERS USA TRUST, et al.,

Debtors.

)
)
)
)
)
)
)

Chapter 11

Case No. 10-13800 (SCC)

Jointly Administered



EXPERT REPORT OF LEE EICHEN SUBMITTED ON BEHALF
OF TRIMONT REAL ESTATE ADVISORS, INC.
I am presently employed as Managing Director and Founding Partner of
Centerboard Group, LLC (Centerboard), a boutique financial advisory firm located at
140 West 57
th
Street, 11
th
Floor, New York, NY 10019. I have over 15 years of mergers
and acquisitions investment banking experience, having begun my career in 1995 at
Salomon Smith Barney, Inc. Prior to forming Centerboard, I most recently ran the Real
Estate Mergers & Acquisitions business of Bank of America Securities, LLC, a leading
global investment banking franchise. In that role, I personally advised clients on more
than $100 billion of real estate mergers and acquisitions deals from 2006 to 2009,
including many industry-leading transactions such as Equity Office Properties ($36
billion buyside on behalf of Blackstone) and Archstone Smith ($22 billion buyside on
behalf of Tishman and Lehman). I also have extensive experience in the lodging sector
in particular, having led the Bank of America advisory teams on Hilton Hotels ($26
billion buyside on behalf of Blackstone), CNL Hotels & Resorts ($6 billion sellside on
behalf of company), Extended Stay ($8 billion sellside on behalf of company), Red Roof
Inns ($1 billion sellside on behalf of company) and others. Additional information on my
educational background and work experience is attached hereto as Exhibit A.
- 2 -

SCOPE OF ENGAGEMENT
I was engaged by Trimont Real Estate Advisors, Inc. (Trimont) to provide my
opinions and conclusions concerning the proposed transactions underlying the Debtors
Motion For Entry of an Order (I) Authorizing the Debtors to Enter Into the Commitment
Letter with Five Mile II Pooling REIT LLC, Lehman ALI Inc., and Midland Loan
Services, (II) Approving the New Party/Midland Commitment Between the Debtors and
Midland Loan Services, (III) Approving Bidding Procedures, (IV) Approving Bid
Protections, (V) Authorizing an Expense Reimbursement to Bidder D, and (VI)
Modifying Cash Collateral Order to Increase Expense Reserve (the Motion).
Specifically, Trimont has requested that I provide my professional opinion on the
following issues:
A. Is the process undertaken to date by Moelis & Company (Moelis) on
behalf of the Debtors (and the process proposed to be undertaken following the hearing
on March 8, 2011 if the Motion is approved) consistent with accepted industry practice
and likely to lead to the highest and best value for the various Debtors and the property of
their respective estates; and
B. Are the bid procedures, bid protections and other proposed terms
contained in the Motion reasonable and appropriate.
SUMMARY OPINIONS AND CONCLUSIONS
Based on my analysis of available financial and other information and the Motion
and related materials submitted by the Debtors, my professional opinions and conclusions
are as follows:
A. THE PROCESS UNDERTAKEN BY THE DEBTORS IS
FUNDAMENTALLY FLAWED AND UNLIKELY TO LEAD TO THE
HIGHEST AND BEST VALUE
- 3 -

1. Marketing the properties exclusively as a whole is not warranted and is
detrimental to value.
a. There is no valid business reason for the properties to remain
together and there is no additional enterprise value attributable to the properties as a
whole.
b. Marketing the properties as a whole detracts from value by limiting
the buyer universe, preventing value-maximizing combination bids and requiring a larger
financing package which is likely to be less competitive.
c. Marketing the properties as a whole creates inter-creditor
allocation issues which are unfair to the mezzanine creditors of the floating rate pool and
the Hilton Anaheim.
2. The Debtors did not involve enough potential bidders in the stalking horse
process although there was adequate time to conduct a reasonably broad marketing
process for this role.
3. The Debtors conduct has led to perception in the marketplace that there is
no meaningful opportunity for an outside party to win control of the assets.
4. The Debtors advisors acted inconsistently with accepted industry practice
and did not take reasonably prudent steps necessary to maximize value.
B. THE BID PROCEDURES, BID PROTECTIONS AND OTHER
PROPOSED TERMS CONTAINED IN THE DEBTORS MOTION ARE
UNREASONABLE AND WILL SIGNIFICANTLY DETER OTHER
BIDDERS FROM PARTICIPATING
1. The bid procedures unreasonably favor the insider bidding group and will
deter other bidders from spending the necessary time and resources to present a
competing offer.
- 4 -

2. The standard for accepting competing bids for less than all of the assets is
unreasonably high.
MATERIALS AND INFORMATION REVIEWED
To prepare this report, I have reviewed the documents relating to the matter In re
Innkeepers USA Trust, et al., Case No. 10-13800 (SCC) in the United States Bankruptcy
Court for the Southern District of New York. In addition, I have reviewed extensive
financial materials relating to the Debtors assets which were posted in the online data
room made available by the Debtors. The deadline for the submission of this report
occurred prior to the opportunity to fully review all relevant documents provided by the
Debtors and other parties and before depositions of witnesses on issues relevant to the
Motion. Accordingly, a review of these documents and the deposition transcripts may
reveal important information that is currently unknown to me and which may materially
alter, vary or expand the opinions and/or conclusions expressed herein.
ANALYSIS
A. THE PROCESS UNDERTAKEN BY THE DEBTORS IS
FUNDAMENTALLY FLAWED AND UNLIKELY TO LEAD TO THE
HIGHEST AND BEST VALUE

The process undertaken to date by Moelis on behalf of the Debtors was
fundamentally flawed in several respects and contrary to sound industry practice. First,
throughout the pendency of these cases, Debtors and their advisors have maintained that
the entire portfolio of 72 properties needs to remain together and be marketed as a whole
in order to capture the value of the enterprise. This view has, to a large extent, led to
the Debtors decision to market the properties as a whole rather than in smaller portfolios
or as individual assets. While this view would be valid for a corporate entity with several
plants or facilities that make up an overall business, it is inapposite to real estate
- 5 -

companies in general and especially inapposite for pure property-owning lodging
companies like Innkeepers.
The lodging industry has evolved over time into companies that focus purely on
brand management (such as Four Seasons), companies that focus purely on property
ownership and outsource all brand functions and property management (such as Host
Hotels), and companies that fall somewhere in between (such as Hilton). Innkeepers
clearly falls into the category of a pure property owner since it operates under franchise
agreements for almost all of its hotels and contracts with a third party management
company to oversee its properties. The Innkeepers corporate office is extremely small in
comparison to the amount of owned real estate (since all of the employees at the hotels
are employed by the management company) and the only functions carried out by the
corporate office are asset management oversight and shared overhead such as finance,
tax, benefits etc. The properties themselves have no relation to one another and
Innkeepers acts essentially as an investment holding company with the corporate entity
virtually unknown to the public.
This reality is well known to real estate investors and is the reason that no
enterprise value is included when calculating the net asset value of a pure property-
owning lodging company. Each asset is typically valued as a stand-alone property based
on its asset-level financials and the value of the overall portfolio is simply the sum of all
the individual properties without any extra value attributable to an enterprise. To the
contrary, keeping the properties together should, if anything, be viewed as a negative
since a buyer could take the position that they are entitled to a bulk discount when
- 6 -

purchasing a large number of properties and that there is additional overhead they need to
deal with if they are forced to take the corporate entity.
Marketing the properties as a whole will also lead to a less competitive auction
and lower expected values since it will severely limit the potential buyer universe.
Lodging assets are generally in high demand at the current time and potential buyers are
made up of individual investors, hotel owner operators, private equity and hedge funds,
institutional investors and pension funds, and public REITs. Many recent properties that
have been marketed on an individual basis or in smaller pools less than several hundred
million dollars in value have garnered significant interest and many bidders. However, a
much smaller number of these many interested parties have sufficient capital or the
overall appetite to pursue a transaction in excess of $1 billion. Because there are far
fewer buyers for a portfolio of this size, the competitive process will not be as robust and
valuation will be lower than it would be if the properties were marketed in smaller pools.
In addition, marketing the properties as a whole will prevent the Debtors from
identifying value-maximizing combination bids. A common strategy employed by
sellside advisors in this type of situation is to market the overall portfolio in pools and
construct a total company bid by partnering up the high bidders on each of the various
pools. I personally employed this strategy very effectively in the $6 billion sale of CNL
Hotels & Resorts in early 2007 by soliciting individual bids and partnering up the high
bidders for a transaction that encompassed all of the properties.
Marketing the properties as a whole will also detract from value by forcing buyers
into a larger financing package. Like the plethora of buyers on smaller assets, a diverse
group of banks and financing sources have been very willing to lend against lodging
- 7 -

assets. However, as the size of the transaction exceeds a couple of hundred million
dollars, far fewer banks will be willing to provide a loan of the required size and one
source of financing, on balance sheet bank financing, will be entirely unavailable. Fewer
banks means less competition and financing terms will suffer thereby negatively
impacting overall value.
Finally, marketing the properties as a whole creates inter-creditor allocation issues
that cannot be determined with any degree of certainty. Because the type of assets vary
widely between the pools and have different investment profiles, one portfolio may be a
better fit for a particular buyer and warrant a higher price under the circumstances. The
only truly valid way to determine relative allocation between the various pools of assets
is to market each separately and compare bids. A negotiated approach without a separate
market-based process will necessarily be open to vast differences of opinion and
uncertainty.
In the Motion, Debtors propose an initial allocation and overbid allocation
procedures to apportion value between the various creditors. This allocation was
purportedly the result of a negotiation between the senior creditors for each of the various
pools. However, this methodology is completely unfair to the mezzanine creditors of the
floating rate pool and the Hilton Anaheim and illustrates the key reason why a market-
based approach is needed. Because Lehman, the senior creditor on the floating rate pool,
is proposing to convert its debt position to equity, they are incentivized to keep the value
of the floating rate pool below par in order to eliminate Trimonts claims. As an equity
holder, Lehmans negotiation with the fixed rate creditors simply becomes a discussion
about how much debt the reorganized company will assume going forward. That is the
- 8 -

reason why, as shown in Exhibit B, as the valuation of the overall enterprise has
continued to rise since the beginning of the bankruptcy case (consistent with overall
lodging market valuations), the allocation associated with the fixed rate pool and the
allocation associated with the seven individual hotels has continued to rise while the
allocation associated with the floating rate pool has remained essentially flat.
The process undertaken by Moelis is also fundamentally flawed because it
unreasonably limited the number of potential bidders that could compete for the role of
stalking horse. Rather than contacting a reasonably wide group of interested parties to
compete for the role of stalking horse, Moelis represented in their declaration that they
chose to contact only four potential bidders (in addition to Five Mile, which identified
itself as a bidder early on). Moelis attributes this decision to not having enough time to
deal with a broader universe of potential buyers, but many months have already elapsed
since the stalking horse process began and the greater number of potential buyers could
easily have been managed by giving interested parties access to the online data room and
requiring an adequate indication of interest before granting access to property visits or
management. This approach is very similar to the process now being undertaken by
Moelis (albeit after having accepted an insider stalking horse bid) and begs the question
why this was not done earlier and whether the current process is mere window-
dressing. Although Moelis appears to have recently opened up the stalking horse process
to additional bidders, it is highly unlikely the bidders that have been recently contacted
will have enough time to catch up and complete their diligence before the March 8
hearing, placing them at a significant disadvantage.
- 9 -

Moelis conduct over the past several months, taken together with the initial filing
of the Plan Support Agreement, has created the impression in the marketplace that the
Debtors are intent on promoting a structured deal with hand-picked partners and that
outside bidders or bidders who want to pursue alternative transactions are at a
disadvantage. There is also some concern in the marketplace about Apollos role and
ultimate participation in any winning bid (before or after plan confirmation) and the fact
that they remain on the Board and privy to competing bids without having declared
whether they intend to participate in the process in the future. Accordingly, there has
been significant reluctance on the part of industry participants to spend the necessary
time and expense to participate in an auction for the Debtors assets.
Finally, Debtors advisors did not act consistently with sound industry practice
and did not take reasonably prudent steps to maximize value. One of the first important
steps typically taken by a sellside advisor in this type of situation is to contact major
financing sources and seek to arrange a stapled financing package which can be used by
any qualified bidder. As of a few weeks ago, it is my understanding that Moelis had not
reached out to any financing sources for a detailed underwriting. Financing may well be
available on better terms than those offered by Midland and in my opinion Debtors
advisors should have pursued other financing options.
In addition, it is my understanding from several interested bidders that they are
precluded from participating in an auction by restrictions contained in prior
confidentiality agreements signed with either Apollo or Five Mile. Despite the fact that I
informed Moelis of this fact, they still did not take any steps to have those provisions
waived in connection with the stalking horse process. Finally, Moelis chose to negotiate
- 10 -

a stalking horse bid without the 2011 budget, key information which is due out in a few
weeks and which I would expect to be highly favorable relative to the current model,
given the recent improvement in overall lodging market fundamentals.
B. THE BID PROCEDURES, BID PROTECTIONS AND OTHER
PROPOSED TERMS CONTAINED IN THE DEBTORS MOTION ARE
UNREASONABLE AND WILL SIGNIFICANTLY DETER OTHER
BIDDERS FROM PARTICIPATING
The bid procedures, bid protections and other proposed terms set forth in the
Motion are unreasonable since they favor the existing insider bidders and place a
competing outside bidder at a significant disadvantage. The proposed bid protections
require that any outside bidder pay Lehman a minimum of $200.3 million in cash rather
than having them continue to convert their senior debt into equity (or leave the debt in
place). Debtors justification for this requirement is that a bidder should be no worse off
since the amount of debt and equity will be the same and the overall debt to equity ratio is
limited by the Midland embedded financing proposal. This explanation fails to note,
however, the key disadvantage that a competing bidder will have to overcome. A
competing bidder will have to raise substantially more cash to put in an equal bid,
whereas Lehman has the advantage of converting its debt to equity without having to
contribute any cash at all. The requirement of raising an additional $200.3 million of
cash in the current environment is a very substantial additional undertaking that every
other bidder besides Lehman will have to achieve. This additional hurdle not faced by
Lehman could, by itself, make the stalking horse bid a foregone conclusion without any
competition. In addition to favoring the stalking horse bidding group, this type of uneven
playing field leads potential bidders to conclude that this is not a fair process and
- 11 -

significantly deters them from committing the time and resources necessary to participate
in an overbid process.
The bid procedures, bid protections and other proposed terms are also
unreasonable due to the fact that the Debtors cannot pursue a superior transaction for less
than all of the properties unless they can show that turning such a bid down would result
in a breach of their fiduciary duties. Potential buyers for less than all of the assets will
view this as an onerous standard to be satisfied before their competing bid can be
accepted and will further reduce their willingness to become involved in a competitive
auction.

Respectfully submitted,

Lee Eichen
Managing Director, Centerboard Group LLC

Centerboard
CONFIDENTIAL
February9,2011
CenterboardExpertWitnessReport-Exhibits
Centerboard
CONFIDENTIAL
ExhibitALeeEichenQualica<ons
Centerboard
CONFIDENTIALIPage2
LeeEichen-Qualica<ons
StorageMart/AcquisiBonofInStorage
KollDevelopment/SaleofEquityInterest
RealEstateSpecialtyFinanceCompany/StrategicReview
ElDorado/AcquisiBonofTropicanaEvansville
Blackstone/AcquisiBonofHilton
TishmanLehman/AcquisiBonofArchstone-Smith
Accor/SaleofRedRoofInns
EquityInternaBonal/ValuaBonAnalysis
Blackstone/SaleofExtendedStayAmerica
SPXCorporaBon/SaleofContech
Blackstone/AcquisiBonofEquityOceProperBes
CNLHotels&Resorts/SaletoMorganStanleyandAshford
GeorgiaGulf/AcquisiBonofRoyalGroupTechnologies
SothebysHoldings/AcquisiBonofNoortmanMasterPainBngs
Fedex/AcquisiBonofWatkinsMotorLines
TheGeoGroup/Follow-onEquityOering
CrestviewAerospace/SaletoL3CommunicaBons
SothebysHoldings/RecapitalizaBon
PrecisionCastParts/SaleofEurovalve
SPXCorporaBon/SaleofVanceInternaBonal
EagleGlobalLogisBcs/RecapitalizaBon
PWCLogisBcs/AcquisiBonofGeoLogisBcs
PrecisionCastParts/SaleofFlowControlBusiness
DigitalNet/SaletoBAENorthAmerica
LockheedMarBn/SaleofInterestinIntelsat
Invensys/SaleofInvensysMeteringSystems
Blackstone/AcquisiBonofOndeoNalco
GeneralDynamics/AcquisiBonofVeridian
Invensys/SaleofRexnordCorporaBon
RFMicroDevice/Resonext
Caraustar/AcquisiBonofAssetsfromSmurtStone
C-MAC/SaletoSolectronCorporaBon
Avaltus/SaletoPrecisionResponseCorporaBon
Caminus/AcquisiBonofAltra
UnionPacicResources/AcquisiBonofNorcen
UnionPacicResources/HosBletenderforPennzoil
AllegianceHealthcare/SaleofLatexGloveBusiness
NSGroup/Follow-OnEquityOering
CoastalPhysicianGroup/SaleofManagedCareBusiness
CommunityCareofAmerica/IntegratedHealth
Equimed-Ophthalmology/PhysiciansResourceGroup
Kidde/SaletoHansonTrustplc
LeeEichenisafoundingprincipalofCenterboardGroup.PriortoCenterboard,Mr.EichenwasaManagingDirectoratBancofAmerica
SecuriBesfor9yearsandwasHeadofM&AforRealEstate,Gaming,LodgingandHomebuilding.PreviouslyatBancofAmerica,hefocusedon
M&AtransacBonsforthegeneralindustrialcoverageuniverse,includingchemicals,transportaBon&logisBcs,aerospace&defense,capital
goodsanddiversiedindustrials.PriortojoiningBancofAmericaSecuriBes,heworkedintheMergers&AcquisiBonsGroupatSalomonSmith
Barney,wherehecompletedtransacBonsinvarioussectors,includingenergy,healthcare,metalsandmining,andtechnology.Priorto
investmentbanking,Mr.EichenwasapracBcingaaorneyatSimpsonThacher&Bartlea.
Mr.EichensM&AexperiencespansawidevarietyoftransacBontypesandincludesmergers,acquisiBons,divesBtures,restructurings,
recapitalizaBons,fairnessopinions,valuaBons,takeoverdefensesandhosBletransacBons.
Mr.EichenreceivedaBachelorofArtsmagnacumlaudeineconomicsfromHarvardUniversityin1989andaJurisDoctorcumlaudeOrderof
theCoiffromtheUniversityofPennsylvaniaLawSchoolin1994.Hecanbereachedatlee.eichen@centerboardgroup.comor(646)442-8702
oce/(917)647-1554cell.
SelectedTransac<ons($MM)
DealSize
$400
ND
ND
250
26,000
22,200
1,300
ND
8,000
146
38,000
6,300
1,600
83
780
125
135
290
ND
67
210
DealSize
$460
116
600
5,100
650
4,350
1,560
925
150
100
2,300
100
125
3,500
6,200
ND
225
ND
100
100
1,600
Centerboard
CONFIDENTIAL
ExhibitBAlloca<onComparison
Centerboard
CONFIDENTIALIPage4
Alloca<onComparison
(1)Source:GreenStreetAdvisors
Centerboard
CONFIDENTIALIPage5
Alloca<onComparison
(1) TotalcapitalizaBonofstalkinghorsebidperBidProceduresMoBon
(2) TotalcapitalizaBonofstalkinghorsebidplustheoreBcal$100mmnetoverbidperBidProceduresMoBon
Dollarsinmillions
US2008 2329951.1

CERTIFICATE OF SERVICE


I hereby certify that on March 1, 2011, a true and correct copy of the foregoing document
was filed electronically with the Courts CM/ECF filing system which in turn will generate an
electronic notice of filing to all those who have requested or consented to electronic service in
these chapter 11 cases.


/s/ Mark A. Fink
Mark A. Fink

You might also like