GMAC states, "The Port Authority and the WTC LLCs havesteadfastly failed to comply with those obligations, despite GMAC'srepeated requests. In order to ensure the protection of thecertificateholders' security interest, GMACCM is compelled to takethis action."

The complaint continues. "As reflected in the various publicstatements of the Port Authority and the World Trade Center LLCsduring the past several months, those organizations have committedto the restoration of the World Trade Center, commencing with theplanned construction next summer of the Freedom Tower designed byStudio Daniel Libeskind. As a result, the Port Authority and theWorld Trade Center LLCs each owe various contractual obligations tothe certificateholders that will protect the certificateholders'security interest."

Central among these obligations is the requirement for the PortAuthority and the World Trade Center LLCs to obtain GMAC's consentto the rebuilding plan and to deposit sufficient funds from theinsurance proceeds to ensure the payment of all amounts due underthe loan during the rebuilding process.