In 2004 and again in 2008, Ms. Kiwanuka signed an employment contract with defendant Anne Margareth Bakilana, pursuant to which Ms. Kiwanuka would travel from Tanzania to the United States to work as a domestic servant for Ms. Bakilana and her husband, defendant Raymond D. Rwehumbiza. Id. ¶¶ 1, 20, 24, 59. Ms. Bakilana and Mr. Rwehumbiza are Tanzanians who come from wealthy and influential families. Id. ¶ 17, 18. At the time of the events in question, Ms. Bakilana was employed in Washington, D.C. as an economist for the World Bank Group. Id. ¶ 13. Ms. Kiwanuka traveled to the United States in 2004 and again in 2009 under a G–5 non-immigrant visa, which was arranged by the defendants. Id. ¶ 12. At the time of her arrival in the United States, Ms. Kiwanuka's English skills were limited. Id. ¶ 14.
When Ms. Kiwanuka first came to the United States in 2004, the defendants lived with their four-month-old son in Rosslyn, Virginia. Id. ¶ 13. In 2005, the defendants moved to Falls Church, Virginia. Id. When the defendants brought Ms. Kiwanuka back to the United States in 2009, they lived with their two sons in Falls Church, Virginia. Id.
Ms. Kiwanuka alleges that the defendants lured her to the United States with promises of reasonable working conditions, educational opportunities, and decent pay. Id. ¶¶ 1, 20, 55. However, Ms. Kiwanuka claims that upon both of her arrivals in the United States, the defendants confiscated her passport, held her in isolation, and used threats of deportation to manipulate her into working long hours as a domestic servant and nanny to their children. Id. ¶¶ 2, 3, 66–68. Believing that if she stopped working for the defendants she would be deported within twenty-four hours, id. ¶ 28, Ms. Kiwanuka worked seven days a week, without breaks to rest or eat, id. ¶¶ 3, 69, 70, and allegedly endured Ms. Bakilana's regular verbal and psychological abuse, id. ¶¶ 35, 36.
In July 2009, the FBI launched an investigation into defendants' employment and exploitation of Ms. Kiwanuka in response to a tip of a possible human trafficking situation. Id. ¶ 4. FBI officers provided Ms. Kiwanuka with a recording device, which she used to record her conversations with Ms. Bakilana. Id. The recorded conversations captured Ms. Bakilana warning Ms. Kiwanuka that she would be immediately escorted out of the country by the FBI if she stopped working for the defendants. Id. Ex. B (“Bakilana Statement”), ¶ 14.
When FBI agents and a federal prosecutor questioned Ms. Bakilana, she willfully and knowingly made false statements about Ms. Kiwanuka's pay and the threats of deportation she used to control Ms. Kiwanuka. Compl. ¶¶ 5, 6. Ms. Bakilana subsequently pled guilty to two counts of knowingly and willfully making materially false, fictitious, and fraudulent statements and representations in a matter within the jurisdiction of the executive branch of the United States government, in violation of 18 U.S.C. § 1001(a)(2). See Compl. Ex. A (“Plea Agreement”), at 1. In the statement of stipulated facts that Ms.