Survivors of the Pulse nightclub attack filed a federal lawsuit Wednesday against the gunman’s wife as well as his former employer, arguing that the deadliest mass shooting in modern American history could have been prevented had they acted.

The lawsuit argues that despite Omar Mateen‘s history of violent threats and comments about terrorism, the 29-year-old was still able to carry out the massacre at the Orlando club last year because of negligence on the part of the security firm where he worked and because of assistance from his wife.

“This attack was easily preventable because it was predictable,” Antonio M. Romanucci, a Chicago-based attorney, said at a news conference announcing the lawsuit.

Dozens of people who survived the attack, along with the estates of seven people killed at Pulse, are listed as plaintiffs in the complaint, which was filed Wednesday morning in the U.S. District Court for the Southern District of Florida.

49 people were killed at a nightclub in Orlando when a gunman who pledged loyalty to the Islamic State opened fire and took hostages. Here are the victims. (Victoria Walker/The Washington Post)

Mateen was killed in a shootout with police following an hours-long standoff with authorities, during which he remained with hostages in the club’s bathrooms and pledged allegiance to the Islamic State. The attack killed 49 people and injured more than 50 others, some of whom recalled being shot multiple times as Mateen sprayed bullets across the club.

“A bullet had hit my pinkie,” Ilka Reyes, a plaintiff in the new lawsuit, said while describing her experience during the news conference Wednesday. “It was when I was being pushed to the ground that I noticed my finger was gone.”

Pausing to wipe her eyes and appearing visibly shaken as she recalled the screaming inside the club, Reyes described being urged to try to keep quiet while she was on the ground.

“I kept quiet, but it didn’t help,” she said. “Next thing I knew, there was a shadow next to me. And I was being shot in the back eight times. With every shot, my body jumped and I could feel blood coming out from my mouth.”

The complaint names Noor Salman, Mateen’s widow, as one of the defendants. The FBI arrested Salman in January and charged her with aiding and abetting terrorism. Echoing federal prosecutors’ arguments, the new lawsuit accuses Salman of “knowingly assisting” Mateen in planning the attack, helping him purchase firearms and ammunition and surveilling the club.

Salman’s attorneys have argued that she was “physically and financially abused at the hands of Mateen,” saying in court filings that she was not aware of “her husband’s murderous plans.” An attorney for Salman declined to comment Wednesday because he had not yet read the new lawsuit.

Mateen’s first wife said that he was “not a stable person” and that he repeatedly beat her. His behavior also drew the attention of the FBI, which opened a preliminary investigation after Mateen’s co-workers reported that he had claimed he was a member of Hezbollah and had family connections to al-Qaeda. The co-workers also said that Mateen spoke of dying as a martyr and claimed to share acquaintances with the Boston Marathon attackers.

The FBI ultimately closed its investigation into Mateen in early 2014 after investigators concluded he was not a threat. He also cropped up during a separate probe that year into an American who flew to Syria and died in a suicide attack linked to al-Qaeda, but authorities found no clear ties between the men.

In 2007, Mateen began working for the London-based security firm G4S, which has more than half a million employees and operates in about 100 countries. He became a licensed security guard with a permit to carry a concealed weapon.

The new lawsuit argues that G4S wantonly ignored warning signs, including Mateen’s references to terror groups, the FBI investigation and his threatening comments. It also argues that the company could have had Mateen go through a new psychological evaluation or could have tried to have his firearms license revoked.

In a statement, G4S said that while it continues to have sympathy for all of Pulse’s victims, the company “intends to vigorously defend itself against the lawsuit which it considers to be wholly without merit.”

Romanucci, the lawyer who announced the lawsuit Wednesday, said the survivors and relatives are seeking monetary damages, but said that they have not determined a specific amount. Calling the toll from the attack “incalculable,” Romanucci said the lawsuit aims to seek justice and prevent other massacres, noting that he also hopes it can lead to changes in the way people like Mateen are able to buy mass amounts of ammunition and assault-style rifles.

In an interview, Romanucci said the lawsuit focuses on Mateen’s wife and the company because they “had the most responsibility” for what happened.

By focusing on an attacker’s family and workplace, the lawsuit differs from some of the high-profile litigation related to other recent mass shootings; those lawsuits have focused on other aspects of the slayings.

After a gunman opened fire inside an Aurora, Colo., movie theater in 2012, dozens of victims unsuccessfully sued the theater company and argued that its security setup allowed the attack to happen. In Connecticut, relatives of people killed at Sandy Hook Elementary School the same year sued the gun manufacturers and sellers and argued that they are liable for the shooting. So far, those relatives have been rebuffed due to the federal shield law, which was passed by Congress in 2005 and provides broad protection to gun companies against liability suits; the relatives are appealing the case’s dismissal.

Some relatives of the Pulse victims also filed a lawsuit late last year against Google, Twitter and Facebook, arguing that the companies played a role in the attack because they helped fuel the Islamic State’s growth.

This story has been updated. It originally said that Salman was named as a plaintiff, rather than a defendant.

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