Arizona Kracken lawsuit

Case 2:20-cv-02321-DJH Document 1 Filed 12/02/20 Page 24 of 53
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
F. USB drives with vote tally information were observed to be
removed from the presence of poll watchers during a recent
election.
G. “The security risks outlined above – operating system risks, the
failure to harden the computers, performing operations directly
on the operating systems, lax control of memory cards, lack of
procedures, and potential remote access are extreme and destroy
the credibility of the tabulations and output of the reports
coming from a voting system.” Id. 49.
7. Foreign Interference/Hacking and/or Manipulation of
Dominion Results.
a. The Origins of Dominion Voting Systems
74. Smartmatic and its inventors have backgrounds evidencing foreign
connections with countries such as Serbia. Upon information and belief, the
inventors listed below have such connections:
Applicant: SMARTMATIC, CORP.
Inventors: Lino Iglesias, Roger Pinate, Antonio Mugica, Paul Babic,
Jeffrey Naveda, Dany Farina, Rodrigo Meneses, Salvador Ponticelli,
Gisela Goncalves, Yrem Caruso 8
75. Another Affiant witness testifies that in Venezuela, she was in official
position related to elections and witnessed manipulations of petitions to prevent a
removal of President Chavez and because she protested, she was summarily
dismissed. She explains the vulnerabilities of the electronic voting system and
Smartmatica to such manipulations. (See Ex. 17, Cardozo Aff. 8).
b. US Government Advisory on Vulnerability to Foreign
Hackers.
76. In October of 2020 The FBI and CISA issued a JOINT CYBERSECURITY
ADVISORY ON October 30, 2020 titled: Iranian Advanced Persistent Threat Actor
Identified Obtained Voter Registration Data
8
See Patents Assigned to Smartmatic Corp., available at:
https://patents.justia.com/assignee/smartmatic-corp
- 24 -