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(Spacing added by me)
Co-plaintiffs Chris Hemwall, Patrick Shelley and Zackary Hombel were wounded in the March 19, 2011 shootings at Forward Operating Base Frontenac.
"The Tundra security guard had previously been fired by Tundra because he had threatened to attack United States troops," the complaint states. "At the time that he was fired, Tundra's manager specifically recommended that this individual, who posed such a dangerous threat, not be rehired. Tundra failed to properly document the guard's threats, the circumstances of his firing, and failed to report to the United States military the danger the guard posed to U.S. and coalition military forces.
As a result of Tundra's actions and inactions, the security guard was rehired by Tundra." The complaint adds: "Within days of being rehired by Tundra, he carried out his prior threats with the weapon provided by Tundra. The guard launched an attack, killing Rudy Acosta and Donald Mickler Jr. inside the 'protected' security zone at FOB [Forward Operating Base] Frontenac.
A later search of the shooter's quarters by U.S. military investigators revealed large amounts of different types of narcotics, including hashish and opium."
"The [November 2009] agreement required that Tundra perform ordinary and necessary safety precautions to protect the men and women living, working and serving at FOB Frontenac. Among other things, Tundra was required to screen and vet security guards, ensure that the guards were properly processed and that documentation was in place for any security guards who were disciplined or fired, and monitor the guards in general, and to prevent the use of possession of drugs/narcotics by the guards."