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, W 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 second applicant herein. 2. That about April 2008, I applied for placement for a job of supermarket sales woman in Iraq for American supermarkets, at Uganda Veterans Development Ltd offices at Muyenga, Kampala. That I paid the application fee of Ush 50,000/- and Ush 2,000,000/for the air ticket to a one Kyarimpa, an officer in the UVDL office but no receipt was issued to me. That I was asked to wait for the opportunity and that I would subsequently be taken to Iraq. That on 14th March 2009, UVDL flew me and other 13 girls to Bagdad airport via Nairobi and Dubai.

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That I together with the 13 other girls were taken to Abu Samis office in Bagdad and Abu Sami took away our passports and told us that he had purchased each of us at the cost of US$ 3,500 and that we had to work for the people he would send us to. That on the same day Abu Sami placed me in the hands of a lady and instructed me that I would work for her as a house maid and I was by this time too tired to protest and so I went to this ladys family. That in this family the work I did was to mop the house wash the dog and clean its feaces and wash their two cars and sweep the compound. The work would go on upto 2:00am when I would sleep. That in the family there was an old man about 70 years, who always sexually harassed.

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10. That after 2 months I received a call from my father in Ntungamo and I informed him that I was suffering greatly, working without pay, working without rest and being sexually harassed and my father promised me to report my complaints to the UVDL. 11. That my father contacted Mr. Kyarimpa of UVDL and my father when he next called me he told me that Kyarimpa had suggested that I be placed in a different family. 12. That because of what I was going through I failed to work and the family took me back to Abu Sami after about 2 months of my work with the family. 13. That when Abu Sami saw me in his office he slapped me calling me a lazy slave and I bust my eardrum and blood oozed therefrom. 14. That I was subsequently detained in a room near Abu Samis office where I found about 6 girls from Uganda also detained. 15. That of the 6 girls I found in detention some were crippled by too much work and looked emaciated and dehydrated and one was pregnant from a rape visited upon her by her employer and the situation was deadly.

16. That Abu Sami gave me a second chance and placed me with another family of a lady with two toddlers and I was tasked to look after them and so I left the 6 girls in detention and went to slave away again. 17. That in this family I cared for the babies, cleaned the house and washed the clothes and their car and at about 2:00pm I would be collected and taken to my boss mother where I would clean the house, wash clothes, the car and water the flowers and sweep the compound and I would work upto 1:00am and I would then sleep and wake at 5:00am do some work and I would be collected back to the family to resume the work there. The work was too much and I fell sick. 18. That a one Julius, a Ugandan working as a guard in Iraq had given me Major General Kale Kaihuras telephone number when I had complained to him about the slavery in Iraq. 19. That I decided to call Major General Kale Kaihura on his mobile phone and informed him about our situation of slavery in Iraq and he promised to rescue us but did nothing to that effect. 20. That I worked in this family for 2 months and because I fell sick due to the weight of the work I told my boss that I could not work anymore. 21. That my boss was angry and she returned me to Abu Sami who again battered me but I was firm that I will not slave away again and so he detained me again and I found another set of 4 girls in detention including V. 22. That the next day still in detention another girl in this application called X arrived in a very bad shape. She was carried into the room and she could not talk nor move herself to the toilet and could not wash herself. 23. That my later boss had bought for me a katoochi mobile phone on which to inform her about her babies and so I had left her employment in possession of a phone.

24. That when Abu Sami was putting me in detention he searched me for a phone but I had hidden it with another slave who was working in Abu Samis office, another Ugandan. 25. That while in detention my sister in this application Y informed me that she had successfully escaped to an American military base and she advised us to do the same and she had already alerted the American military and the Ugandan guards. 26. That I and another girl called V, planned our escape and followed advice given to us by a one Sam, a Ugandan guard at the American military base. 27. That I and V asked Abu Sami for our passports telling him that we wished to go to Bagdad Airport to look for our brother who might have money and he sponsors our air tickets back home. 28. That Abu Sami refused to give us our passports but told us to leave if we wished since he was sure we might be bombed or if lucky arrested by the Iraqi police. 29. That we took the bluff and left our detention and managed by Gods Grace to reach a place called Flying Man where after waiting for about an hour in the deep heat of Bagdad, the American military came and took us to their base where we stayed, received medical and psychological treatment for 2 months. 30. That during the period we were at the American military base, Lt Col. Theodore Lockwood was our godfather who cared so much for us and he tried to reach some of our relations in Uganda. 31. That the American military contacted the International Organisation for Migration who repatriated us back to Uganda. 32. That I suffered slavery, servitude, overwork, nonpayment for work, sexual harassment, loss of my liberty, assault and battery, insults and abuses on account of the deception made upon me by the Uganda Veterans Development Ltd, which induced me into slavery in Iraq.

33. That the Inspector General of Police inspite of pleading with him on phone that I and many Ugandan girls were slaving away in Iraq did nothing in defiance of his constitutional duty to protect me and all Ugandans from harm. 34. That the Ministry of Labour failed in its supervisory role by not caring to see whether or not there were valid contracts of employment for us in Iraq before licencing UVDL to export us as labour. 35. That I know that only 14 of us managed to escape slavery but more than one hundred and fifty Ugandan women continue to slave away in Iraq even when this issue has been raised on the floor of Parliament. 36. That I swear this affidavit in support of my application for prayers that that government does its constitutional duty and rescues the Ugandan women slaving away in Iraq; that the DPP carries out his constitutional duty and prosecutes the directors of UVDL; that I be awarded damages for slavery visited upon me. 37. That what I have stated hereinabove is true to the best of my knowledge, belief and or information as herein above applicable. Sworn at Kampala this day of ................................. 2011. By the said W ................................... 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