THE REPUBLIC OF UGANDA IN THE HIGH COURT AT KAMPALA (CIVIL DIVISION) MISC CAUSE NO. OF 2011 V W X Y Z .....

. APPLICANTS VERSUS 1. 2. 3. 4. ATTORNEY GENERAL OF UGANDA THE INSPECTOR GENERAL OF POLICE THE DIRECTOR OF PUBLIC PROSECUTION THE UGANDA VETERANS DEVELOPMENTS LTD RESPONDENTS AFFIDAVIT IN SUPPORT OF MOTION I, V of C/o M/s Rwakafuuzi & Co. Advocates, Plot 7 Luwum Street Mulji House, P.O. Box 26003, Kampala Email: kalr@utlonline.co.ug do solemnly make oath and state as follows 1. That I am an adult female Ugandan of sound mind and the first applicant herein. 2. That I was in October 2008 recruited by M/s Uganda Veterans Development Ltd hereinafter referred to as UVDL for a teaching job in Iraq after the UVDL had seen my papers showing that I am a qualified (OLevel) teacher and after I had paid to UVDL Ush 2,000,000/- for visa, air ticket, medical examination fees, application fees and registration fees. That I was informed by the said UVDL the fourth respondent herein that I would work for Americans in Iraq either in my profession as a teacher or as a sales person in American supermarkets. That l learnt of UVDL as a recruitment agency from radio adverts about October 2008. That UVDL secured for me an air ticket a copy of which is herewith attached and I left for Iraq on 19th February 2009. That I reached at

3.

4. 5.

Bagdad Airport at night and I, in the company of 9 other Uganda women recruited by UVDL spent the night at Bagdad Airport. 6. That in the morning of 21st February 2009 I together with my 9 colleagues were picked from Bagdad Airport by a gentleman whose name I did not get and he took us to Bagdad town, and he took along with him our passports. That when I together with 9 women arrived in Bagdad town we were taken to an office where I came to learn that the office belonged to the person who had bought us from Uganda, called Abu Sami. That a gentleman whom I came to learn that he was called Abu Sami and owner of the office where we were, welcomed us in some broken English and offered us some water. That the said Abu Sami introduced us to some couples with their children who seemed to have been waiting for us.

7.

8.

9.

10. That the said Abu Sami told us that we were going to work for those families as house maids. 11. That I and my colleagues immediately protested telling Abu Sami that we had not been recruited to work as house maids because the recruitment agency UVDL told us that we would work as professionals or sales persons in super markets. 12. That Abu Sami informed us that the only work he had was for house maids only. 13. That Abu Sami asked us to refund his US$ 3500 the amount he had purchased each of us from UVDL and on top of that we should pay for our own return tickets to Uganda. 14. That I immediately realized that we had been sold into slavery and because I had no such money I submitted to be taken by one of the families and Abu Sami gave my passport to that family. 15. That the first family communication was by because Abu Sami had Muslim and that family Arabic whereas I didnt. which took me knew no English and sign language which annoyed the family told the family in my presence that I was took it for granted that I therefore spoke

16. That because my bosses were annoyed with me right from the start due to the language barrier I was mistreated by them till after about 9 days when the family took me back to Abu Sami and the family handed my passport back to him. The family was compensated with another girl from Uganda. 17. That I was not paid for the 9 days I worked for the first family. 18. That upon arrival at Abu Samis office, Abu Sami beat me saying that I had refused to work but he gave me a second chance with another family and he handed my passport to the new family. 19. That I was taken to the second family composed of two children, one wife, the boss mother, two sisters and one brother who lived in a mansion of over 30 rooms. 20. That my boss knew some workable English but the other members didnt. 21. That in this family there was too much work requiring me to wake up before 5:00am and sleep after 2:00am and I was fed on water and bread and my male boss raped me several times. 22. That most of the work consisted of cleaning and dusting the house and cars which dust continued to fall continuously. 23. That I broke down due to the weight of work and sleeplessness and bad food and sexual harassment from my boss and after 4 months I found it very hard to work any further. 24. That during the four months I was in this family I was constantly scared of being killed because of military drills which seemed to be taking place privately in this home and the members of the home seemed to fear about my loyalty to them wondering if I had contact with the Americans. 25. That during the four months I was in this family I was always locked inside the house when the members of the family would go out and I was not allowed to communicate with any person and all phones in the house were outside my reach.

26. That when I left Uganda, UVDL had told me that I would be paid US$ 800 including allowances by employees in Bagdad and UVDL opened a bank account in my names to that effect. 27. That when I in the company of 9 women arrived in Bagdad at Abu Samis office, I was informed by Abu Sami that the family taking me to employ me would pay me US$ 200 and I with my colleagues protested saying that UVDL had informed us that we would be paid US$ 800. 28. That Abu Sami informed us that the US$ 200 was the money he and UVDL had agreed on to pay [the women] us. 29. That when I was placed to work in the first family we never had a chance to discuss the issue of payment because of lack of communication. 30. That when I was placed to work in the second family I begged to be paid at least more that US$ 200 but my boss categorically said he had purchased me a lot of money from Abu Sami whom he continues to pay monthly and had paid for my air ticket and therefore he refused. 31. That in the second family I was paid US$ 200 for only two months and I was not paid for the other 2 months. 32. That I was so heartbroken and very sick and I was failing to work and I told my boss that I had come to Bagdad with my sister and I wanted to see her. 33. That my boss accompanied me to Abu Samis office and my boss took my passport with him to Abu Sami and once I reached there I refused to move any further which brought the wrath of my boss and Abu Sami on me and they beat me badly accusing me of treachery. 34. That during this episode of my beating I heard voices of women, who were speaking Luganda behind the office, locked in a room. 35. That upon my refusal to go back to slave away again, Abu Sami grabbed me and took me to the room with the Ugandan girls threatening to keep me there for the period of my contract i.e. two years.

36. That Abu Sami gave me an alternative to being locked up, that is by refunding the purchase price of US$ 3500 he paid to UVDL and to pay for my return ticket. 37. That after one day of my imprisonment another Ugandan girl in this application called W was brought in. 38. That after the second day of my imprisonment another Ugandan girl in this application called X was brought in and she was very sick and we feared she might die we were carrying her to and from the toilet and feeding her through the mouth. Now we had become about 6 in number. 39. That during the period of our captivity we drank only tap water, no food. 40. That during our captivity, W received a call on her mobile phone from her sister in this application called Y, that Y had successfully escaped to an American Army base. 41. That about 3 girls in our captivity had already communicated to Hon Hussein Kyanjo a Ugandan Member of Parliament in Uganda and UVDL and had been promised some relief. 42. That I and W started plotting our escape from captivity following the tips W had received from her sister Y. 43. That Y had told her sister W that she had informed the American and Uganda security guards working in Iraq about our plight in captivity in Abu Samis office and the American and Ugandan guards devised a plan for us to escape to a place they told us to go to. 44. That in pursuance of our escape plans, we begged Abu Sami to give us back our passports but he refused insisting that we refund the money he paid to UVDL when purchasing us. 45. That we begged Abu Sami to allow us go to the airport Bagdad so that we could find persons who would give us money for our return tickets to Uganda, and he said that if you want you can go the police will arrest you, or the army will kill you but he refused to give us our passports.

46. That we decided to escape without our passports and we left Abu Samis captivity and with difficulty and risk reached the place called Flyingman where a Ugandan guard called Sam had agreed to meet us and we waited for about an hour before Sam arrived in a convoy of many American military vehicles including a tank and picked us and took us to the American base. 47. That when we reached at the American base we were welcomed by Ugandan guards working at the American base who cried on seeing the state in which we were. We were terribly sick and malnourished. 48. That we were introduced to Lt. Col. Theodore Lockwood and other Americans who took great care of us and gave us medical treatment and comfort. 49. That the four girls we left in Abu Samis captivity also escaped after 3 days and joined us at the American military base. 50. That other girls escaped from the various families where they slaved and came to the American military base. 51. That within a month of my escape to the American base we now numbered 14 escapees. 52. That the American military contacted the Iraq judicial and police authorities and formerly reported the case of our having been sold into slavery and consequently one of the employers who had raped and impregnated one of us was imprisoned and Abu Sami was imprisoned, and the Iraqi judge advised that the company that had sold us into slavery should compensate us once we returned to Uganda. 53. That the American army contacted the International Organisation for Migration, IOM, which eventually repatriated me and 13 other girls back to Uganda. 54. That I suffered slavery, forced labour, sexual harassment, bad food, insults, sleeplessness, abuses and assaults all on account of my having been sold into slavery by the UVDL. 55. That I know that the Ministry of Labour was informed about my plight and the plight of the other girls in Iraq but cared not in total disregard of the governments constitutional duty to protect us from harm.

56. That I learnt from W that she personally called and talked to the Inspector General of Police, Kale Kaihura about the plight of the girls in Iraq and he promised to intervene but did nothing in total disregard of his constitutional duty to protect me and other Ugandans from harm. 57. That I know that it is an offence to sell a person into slavery but the DPP inspite of knowing that the directors of UVDL sold me and others into slavery has not commenced prosecution of the culprits in total disregard of his constitutional duty. 58. That I am reliably informed that more than one hundred and fifty girls are slaving away in various homes in Iraq without any relief in sight and it is possible that some could have died. 59. That I swear this affidavit in support of my application that government carries out its constitutional duty and rescues its people in Iraqi slavery, the DPP carries out his constitutional duty and prosecutes the directors of UVDL for offences of slavery and an award of damages on account of what I suffered when I was sold into slavery. DEPONED at Kampala this .. day of .................. 2011. By the said V ................................... Deponent Before me;

................................. Commissioner for Oaths

Drawn/filed by; M/s Rwakafuuzi & Co. Advocates Plot 7 Luwum Street, Mulji House P.O. Box 26003, Kampala Tel: 0414 258136, 0772406906 Email: kalr@utlonline.co.ug