UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA LOUIE NABONG, : : Plaintiff, : Civil Action No.: 17-0400 (RC) : v. : Re Document No.: 8 : OFELIA PADDAYUMAN and : MARIA CRISTINA LOUISE SY, : : Defendants. : MEMORANDUM OPINION DENYING DEFENDANTS’ MOTION TO DISMISS I. INTRODUCTION Plaintiff Louie Nabong brings this action against Defendants, Ofelia Paddayuman and Maria Cristina Louise Sy alleging that Defendants lured Ms. Nabong to the United States with promises of gainful employment, but then isolated and imprisoned her, subjected her to forced labor, and otherwise threatened and mistreated her. This case now comes before the Court on Defendants’ motion to dismiss the Complaint pursuant to Rule 12(b)(3) of the Federal Rules of Civil Procedure for lack of venue or, in the alternative, to transfer the case to the Eastern District of Virginia pursuant to 28 U.S.C. § 1406(a). See Defs.’ Mot. Dismiss (“Defs.’ Mot.”). For the reasons stated below, the Court will deny Defendants’ motion. II. BACKGROUND1 In March 2014, Ms. Nabong was living and working in the Philippines when Ms. Paddayuman contacted her about potential employment in the United States. According to the 1 At the motion to dismiss stage, the Court accepts the plaintiff’s factual allegations as true. See, e.g., United States v. Philip Morris, Inc., 116 F. Supp. 2d 131, 135 (D.D.C. 2000). Complaint, Ms. Paddayuman offered to employ Ms. Nabong in the United States as an “in-home caregiver of [Ms. Paddayuman’s] two grandchildren,” emphasizing “that Ms. Nabong’s responsibilities would be limited to childcare and would not involve cleaning, laundry, or other housework.” Compl. ¶ 16. Enticed by the offer, Ms. Nabong expressed interest in the position. Compl. ¶ 16. Then, a short time later, Ms. Paddayuman informed Ms. Nabong that she had been hired for the job. Compl. ¶ 16. Ms. Paddayuman told Ms. Nabong that “she [Ms. Paddayuman] would handle most of the paperwork associated with Ms. Nabong’s admission to the United States.” Compl. ¶ 17. Defendants then proceeded to secure a G-5 visa for Ms. Nabong, which allows a foreign national to enter the United States as a domestic or personal employee of a foreign employee of an international organization working in the United States under a G-4 visa. Compl. ¶ 18; See Dep’t of State, Visas for Employees of International Organizations and NATO, https://travel.state.gov/content/travel/en/us-visas/other-visa-categories/visa-employees-nato.html. Although Ms. Nabong was consistently told that she would be working for Ms. Paddayuman, throughout the visa paperwork process, Ms. Paddayuman instructed Ms. Nabong to identify Ms. Sy, a World Bank Group employee with a G-4 visa, as her employer both “on the visa” and “during [an] interview with United States embassy officials.” Compl. ¶¶ 18–20. Ms. Paddayuman also provided Ms. Nabong with an employment contract prepared on a World Bank template that identified Ms. Sy as Ms. Nabong’s prospective employer. See Compl. ¶ 22; Compl. Ex. 3, ECF No. 1-3. According to the Complaint, “the preparation of Plaintiffs’ immigration and employment documents, application for and processing of Plaintiffs’ G-5 visa, and ...
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