The wrongful death lawsuit filed by Vanessa Bryant in Los Angeles on Monday said the pilot, Ara Zobayan, was careless and negligent by flying in cloudy conditions and should have aborted the flight. Zobayan was among the nine people killed in the crash.

The lawsuit names Island Express Helicopters Inc and also targets Zobayan’s legal representative, listed only as “Doe 1” until a name can be determined. Vanessa Bryant’s lawsuit asserts that Zobayan was negligent in eight different ways, including failing to properly assess the weather, flying into conditions he wasn’t cleared for and failing to control the helicopter.

The lawsuit was filed as a public memorial service for Kobe Bryant, his daughter, and the other victims, including Zobayan, was being held at Staples Center, the Los Angeles arena where Bryant played most of his career.

Vanessa Bryant spoke at the memorial describing Kobe as “the perfect husband”. She also paid tribute to Gianna. “Her smile was like sunshine,” Vanessa Bryant said. “Her smile took up her entire face. Like me. Kobe always said she was like me. She had my fire, my personality and sarcasm. She was tender and loving on the inside. She had the best laugh. She had the best laugh. It was infectious. It was pure and genuine.”

Zobayan, Bryant’s frequent pilot, had been trying to navigate in heavy fog that limited visibility to the point that the Los Angeles police and sheriff’s departments had grounded their helicopter fleets. Under the visual flight rules that Zobayan was following, he was required to see where he was going. Zobayan was cited by the Federal Aviation Administration in May 2015 for violating those rules by flying into reduced visibility airspace, the lawsuit said.

In his last transmission, Zobayan told air traffic control that he was climbing to 4,000 feet to get above the clouds. He was 100 feet short of breaking through the cloud cover when the helicopter banked left and plunged into a hillside, according to the National Transportation Safety Board.

The NTSB hasn’t concluded what caused the crash in Calabasas, on the outskirts of Los Angeles, but said there was no sign of mechanical failure. A final report isn’t expected for another year.

Island Express is yet to comment on the lawsuit. The company issued a statement in January on its website saying the shock of the crash had prompted it to suspend service for the time being.

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