COMPLAINT-CJ-PEARSON-V.-KEMP-11.25.2020

in an election to recall President Chávez, which Mr. Chávez won handily --
and which the Venezuelan opposition said was riddled with fraud.
Smartmatic put together a consortium to conduct the recall elections,
including a company called Bizta Corp., in which Smartmatic owners had a
large stake. For a time, the Venezuelan government had a 28% stake in Bizta
in exchange for a loan.’ 20 …“Bizta paid off the loan in 2004, and Smartmatic
bought the company the following year. But accusations of Chávez
government control of Smartmatic never ended, especially since Smartmatic
scrapped a simple corporate structure, in which it was based in the U.S. with
a Venezuelan subsidiary, for a far more complex arrangement. The company
said it made the change for tax reasons, but critics, including Rep. Carolyn
Maloney (D., N.Y.) and TV journalist Lou Dobbs, pounded the company for
alleged links to the Chávez regime. Id. Since its purchase by Smartmatic,
Sequoia's sales have risen sharply to a projected $200 million in 2006, said
Smartmatic's chief executive, Anthony Mugica.” Id.
108.
Indeed, Mr. Cobucci testified, through his sworn affidavit, that he born
in Venezuela, is cousins with Antonio (‘Anthony’) Mugica, and he has
20
See WSJ.com, Smartmatic to Sell U.S. Unit, End Probe into Venezuelan Links, by Bob Davis,
12/22/2006, https://www.wsj.com/articles/SB116674617078557263
47