Arizona Kraken lawsuit

Case 2:20-cv-02321-DJH Document 1 Filed 12/02/20 Page 35 of 53
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voting system that permitted the leaders of the Venezuelan government
to manipulate the tabulation of votes for national and local elections and
select the winner of those elections in order to gain and maintain their
power. Importantly, I was a direct witness to the creation and operation
of an electronic voting system in a conspiracy between a company
known as Smartmatic and the leaders of conspiracy with the Venezuelan
government. This conspiracy specifically involved President Hugo
Chavez Frias, the person in charge of the National Electoral Council
named Jorge Rodriguez, and principals, representatives, and personnel
from Smartmatic which included … The purpose of this conspiracy was
to create and operate a voting system that could change the votes in
elections from votes against persons running the Venezuelan
government to votes in their favor in order to maintain control of the
government. (Id. 6, 9, 10).
92. Specific vulnerabilities of the systems in question that have been well
documented or reported include:
A. Barcodes can override the voters’ vote: As one University of California,
Berkeley study shows, “In all three of these machines [including
Dominion Voting Systems] the ballot marking printer is in the same
paper path as the mechanism to deposit marked ballots into an attached
ballot box. This opens up a very serious security vulnerability: the
voting machine can make the paper ballot (to add votes or spoil alreadycase
votes) after the last time the voter sees the paper, and then deposit
that marked ballot into the ballot box without the possibility of
detection.” (See Ex. 10, Appel Study).
B. Voting machines were able to be connected to the internet by way of
laptops that were obviously internet accessible. If one laptop was
connected to the internet, the entire precinct was compromised.
C. October 6, 2006 – Congresswoman Carolyn Maloney calls on
Secretary of Treasury Henry Paulson to conduct an investigation
into Smartmatic based on its foreign ownership and ties to
Venezuela. (See Ex. 15). Congresswoman Maloney wrote that “It is
undisputed that Smartmatic is foreign owned and it has acquired Sequoia
… Smartmatic now acknowledged that Antonio Mugica, a Venezuelan
businessman has a controlling interest in Smartmatica, but the company
has not revealed who all other Smartmatic owners are. Id.
D. Dominion “got into trouble” with several subsidiaries it used over
alleged cases of fraud. One subsidiary is Smartmatic, a company “that
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