Daoud & Partners Inc

Daoud had entered into a number of contracts with the United States for the provision of services at military bases, including Al Asad Air Base in Iraq. Defendant KBR is a business conglomerate; one such KBR subsidiary serves as a contractor with the United States Government to perform specific duties at United States military installations in Iraq. In an effort to fulfill their contractual obligations, the Defendants "willfully and intentionally formed an enterprise with the goal of procuring cheap labor and increasing profits", and therefore engaged in human trafficking. Most of the men were told that they would be employed by a luxury hotel in Amman, Jordan. Some were told that that they would be working in an American camp. They were promised a salary of approximately $ 500 per month. The men and their families incurred substantial debt to pay the brokerage fees in seeking out this employment. The men were held in Jordan by Daoud and agents of Daoud; all of the men were required to turn over their passports to Daoud. It was there that they first discovered that they were actually being sent to Iraq to work on Al Asad Air Base, Iraq. At least one of the men informed his family that he and the other men were being kept in a dark room and were unable to see. The men were also informed that they would be paid only three quarters of what they were initially promised. Daoud transported the victims into Iraq on or about August 19, 2004, via an unprotected automobile caravan. Daoud was aware of the significant and well-known risks involved in traveling on this highway. No security was provided for the caravan. Between August 20 and August 24, the Ansar al-Sunna Army posted an internet statement that it had captured ten (10) of the men, on or about August 31, 2004. International media outlets broadcasted video of the Ansar al-Sunna Army executing the twelve (12) plaintiffs. The group beheaded one of the men, and shot the other eleven men in the back of their heads. Plaintiff BPG’s car was not captured by the insurgents and arrived at Al Asad base as scheduled. He was told by both Daoud and KBR that he could not leave until his work in Iraq was complete. After fifteen months, during which he experienced frequent mortar fire without protection, BPG was permitted to return to Nepal. The plaintiffs alleged that: - KBR knew or should have known prior to August 2004 of the circumstances under which the men were being brought to Iraq to work; - Daoud was previously involved in an incident in which eighteen Indian laborers were forcibly kept in a camp in Fallujah where they worked, although they had quit their jobs months before; - KBR had the authority to terminate all subcontractors who mistreated employees, unlawfully compelled employees to perform work, or unlawfully compelled employees to remain somewhere against their will. https://sherloc.unodc.org/cld/case-law-doc/traffickingpersonscrimetype/usa/2009/adhikari_et_al._v._daoud_partners_et_al.html