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, Z 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 fifth applicant herein. 2. That about July 2008, I was introduced to Uganda Veterans Development Ltd by a dad of a friend of mine who was already in Bagdad called Kisakye Doreen and I visited UVDL at Muyenga where I met a gentleman called Kyarimpa who told me about the opportunities of work in Iraq, Jordan, Dubai and Afghanistan. That he asked me to pay Ush 200,000/- as an application fee which I paid to Kyarimpa but received no receipt. That I kept visiting UVDL trying to find out about the progress of my application but about August 2008 Brenda the cashier of UVDL told me that I had not paid the application fee of USh 200,000/- and that I would have to pay it again. That in March 2009 I received a call from Kyarimpa that my visa and air ticket were ready and I was asked to pay Ush 1,500,000/- for the

3. 4.

5.

visa, application fee, the UVDL t-shirt and medical treatment fees and I paid the money. 6. That I was informed that I was going to work as a maid for the Americans in Iraq and I would be paid US$ 300 per month and allowances which would total to US$ 350 or US$ 400 per month. That on 31st March 2009 I came to UVDL office ready to leave for Iraq and I was asked to sign some forms and I requested to read through but they refused me to read claiming that there was no time because the taxi to take me to Entebbe was out waiting for me and other 9 girls. That we left Entebbe airport by Ethiopian Airlines via Ethiopia to Dubai and then Bagdad and from Bagdad airport we were picked by a man sent by ABU Sami who tool our passports from us and took us to Abu Samis office. That Abu Sami called some people on his phone and told me that they were going to pick me and take me to work for them as a housemaid and when these people came I saw that they could not speak English and they were no Americans and I then protested to Abu Sami that I had come to Iraq to work for Americans and Abu Sami told me that the contract he signed with UVDL where he purchased me was for me to work as a house maid for Iraqi families.

7.

8.

9.

10. That I found myself without a choice and so the family of four people took me. 11. That I worked in this family taking care of the baby, cleaning the house, washing clothes, cleaning dishes the bathroom, the oven, washing the cars and washing the fence the windows ironing clothes and I would start work at 6:00am and sleep at 11:00am 12. That my boss raped more than 6 times but beat always before raping me till he infected me with a venereal disease which fact came to be known by his wife which in turn annoyed the wife and she hit me. 13. That I boycotted and demanded that I be taken back to Abu Sami and after a struggle I was returned to Abu Sami who I begged to return me to Uganda and he refused hitting me several times, reminding me that he had purchased me from UVDL on a two years contract.

14. That the 6 months I worked for this family I was paid only US$ 600 for 3 months and I never received the allowances Kyarimpa had told me I would receive. 15. That Abu Sami sold me to another agent called Mohamed at Us$ 3500 and Mohamed found me another family which had 7 permanent people but with too many relatives who always came and spent some days and left and the house was very big with 6 bathrooms, 6 toilets, 3 storied, and I had to clean it everyday including washing the car the garage the gardens ironing, washing clothes and dishes, cleaning windows and I worked in this family for 8 months. The work made me sick. 16. That in this family my boss the man was above 50 years old and he begged me to have a relationship with him I refused but he was so persistent and his wife came to suspect the mischief, was very annoyed with me and one day she asked me to pack up my things and I was paid US$ 200 per month for 6 months and I was not paid for two months. 17. That Mohamed who had purchased me from Abu Sami came to this family and brought another family which wanted to take me and I protested because I wanted to return home due to what I had suffered and I called UVDL in Muyenga and UVDL advised me to talk to Abu Sami who refused to allow me to return home. 18. That Mohamed insisted that I must work and finish my contract with him and so the family took me and it was big family of over 30 people for whom I had to wash clothes, cook food, clean the house, garages cars, sweep everywhere and I worked for about 3 months and I fell sick and I was hospitalized and my doctor advised that my works schedule should be reduced because of the stress and depression and anxiety 19. That when I returned from hospital I never rested and I there again called UVDL for relief they refused and I called Mohamed who refused and I fell sick again and I was hospitalized another 3 times and on that last the doctor suspected a heart attack,. 20. That about October 2010 I called Kyarimpa and Gordon and their phones were not available and I called Grace Kanyike and talked to her about my problems and she promised to ask Kyarimpa to follow

up my problems and Kyarimpa called and told me that UVDL was no longer handling those matter and could therefore not help. 21. That I could not escape because the family had my passport and I had spent my little salary on hospital bills, telephone calls and so I had no way out and inspite of my sickness I continued to work. 22. That the family continued reminding me that they had purchased me at US$ 3500 and if I could refund it they would let me go if I could also pay for my return ticket. 23. That about December 2010 I called UVDL again begging for relief and Kyarimpa told me that UVDL had been closed and it therefore was no longer concerned about me and others and that I would have to find my own means back home. 24. That about February 2011 I received a call from V who wanted to confirm if I was in need of assistance to return home and I told her yes. 25. That I later received a call from Ms Anna Cavell who introduced herself to me as BBC journalist and she wanted to know about my situation and I told her it was distressful. 26. That about 10th March 2011 the family took me to Abu Samis office who still refused to release my passport contending that I had not completed my contract and so the family took me back to Mohamed who ordered me to go back to work and I refused and so Mohamed agreed that he would contribute half for my air ticket and I told him I had no money and so Mohamed agreed to pay for the air ticket to Entebbe. 27. That on Sunday 20th March at 2:00pm I arrived at Entebbe Airport. 28. That I suffered slavery. 29. That I swear this affidavit in support of my application for my various prayers against the respondents. 30. 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 Y ................................... 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