WILMINGTON, Del. - The trustee in the Chapter 11 bankruptcy proceeding of Filene's Basement LLC on Sept. 24 filed a brief in the U.S. Bankruptcy Court for the District of Delaware, arguing that the ground lease between Filene's affiliate Syms Corp. and its landlord required Syms to pay $3.47 million in rent (In Re: Filene's Basement LLC, No. 11-13511, Chapter 11, D. Del. Bkcy.).