5. The Complainants aver that on 16 June 2017 the Victim met the agent as agreed. He escorted the Victim to a health facility for the yellow fever vaccination. Once the vaccination certificate was issued to the Victim, the agent informed her that she was required to travel to Namibia from Nairobi on the same day by road. The Complainants state that the agent booked and paid for a bus ticket for that evening, and the Victim departed Nairobi at 06:30pm on the same day. 6. The Complainants submit that the bus journey took her through Arusha, Dar-esSalaam, Mbeya and Tunduma in Tanzania, and through Nakonde and Lusaka in Zambia. At the border crossing points in Kenya, Tanzania and Zambia, the Victim was in control of her passport and completed all the border checks together with other passengers on the bus. However, the Complainants aver that, at the Namibian border control p oint, the driver of the bus asked her for her passport and processed her entry into Namibia, while she remained seated in the bus. 7. The Complainants submit that on 22 June 2017, upon entering Namibia, the Victim was handed by the bus driver to two men who demanded that she hand over her travel documents and mobile phone to them and was escorted to a red Volkswagen passenger vehicle. They arrived in Windhoek on the morning of 23 June 2017, and she was taken to a guesthouse with other young women, where she spent ten days. 8. The Complainants aver that on the eleventh day, one of the men in charge of the guesthouse summoned the Victim together, with other young women, to the living room, where they found eight men waiting. The men chose a woman with whom they would have sexual intercourse, including the Victim. The Victim reported that the man raped her repeatedly. 9. The Complainants state that the Victim thereafter, for a three-month period, was sexually exploited and raped by approximately two hundred men. During this period, the Victim was subjected to forced oral and anal sex, forced sexual intercourse with women, forced to use sex toys, forced participation in or~e , sexual ae; that involved physical bondage and the exercise of 'dominance' w~ere she would b ~suspended from the ceiling and whipped. I 10. According to the Complainants, the perpetrators would burn\lcig'a,e~ s on the Victim's breasts, forced her to get into a physical fight with anoth<!r )'QU g woman and, on many occasions, these activities were digitall .," cqrded ~y B'se sexually exploiting her. The Complainants allege that the Victim be ••u~~. gi;ant in August 2017, and was forced to terminate the pregnancy. Further, on several occasions, the Victim was forcibly injected and drugged with unknown substances. As a result, the 2