Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.76 Filed 11/25/20 Page 1 of 8 DECLARATION OF

I, , hereby state the following: 1. 2. I am an adult of sound mine. All statements in this declaration are based on my personal knowledge and are true and correct.

   3.    I am making this statement voluntarily and on my own initiative. I have
         not been promised, nor do I expect to receive, anything in exchange for my
         testimony and giving this statement. I have no expectation of any profit
         or reward and understand that there are those who may seek to harm me
         for what I say in this statement. I have not participated in any political
         process in the United States, have not supported any candidate for office
         in the United States, am not legally permitted to vote in the United
         States, and have never attempted to vote in the United States.

   4.    I want to alert the public and let the world know the truth about the
         corruption, manipulation, and lies being committed by a conspiracy of
         people and companies intent upon betraying the honest people of the
         United States and their legally constituted institutions and fundamental
         rights as citizens. This conspiracy began more than a decade ago in
         Venezuela and has spread to countries all over the world. It is a conspiracy
         to wrongfully gain and keep power and wealth. It involves political
         leaders, powerful companies, and other persons whose purpose is to gain
         and keep power by changing the free will of the people and subverting the
         proper course of governing.

   5.
                                              Over the course of my career, I
         specialized in the marines

   6.    Due to my training in special operations and my extensive military and
         academic formations, I was selected for the national security guard detail
         of the President of Venezuela.
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Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.77 Filed 11/25/20 Page 2 of 8 Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.78 Filed 11/25/20 Page 3 of 8 sophisticated electronic 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.

 10. 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.

 11. In mid-February of 2009, there was a national referendum to change the
     Constitution of Venezuela to end term limits for elected officials, including
     the President of Venezuela. The referendum passed. This permitted Hugo
     Chavez to be re-elected an unlimited number of times.

 12. After passage of the referendum, President Chavez instructed me to make
     arrangements for him to meet with Jorge Rodriguez, then President of the
     National Electoral Council, and three executives from Smartmatic.
     Among the three Smartmatic representatives were

                    President Chavez had multiple meetings with Rodriguez
      and the Smartmatic team at which I was present. In the first of four
      meetings, Jorge Rodriguez promoted the idea to create software that
      would manipulate elections. Chavez was very excited and made it clear
      that he would provide whatever Smartmatic needed. He wanted them
      immediately to create a voting system which would ensure that any time
      anything was going to be voted on the voting system would guarantee
      results that Chavez wanted. Chavez offered Smartmatic many
      inducements, including large sums of money, for Smartmatic to create or
      modify the voting system so that it would guarantee Chavez would win
      every election cycle. Smartmatic’s team agreed to create such a system
      and did so.

 13. I arranged and attended three more meetings between President Chavez
     and the representatives from Smartmatic at which details of the new

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Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.79 Filed 11/25/20 Page 4 of 8

     voting system were discussed and agreed upon. For each of these
     meetings, I communicated directly with                     on details of
     where and when to meet, where the participants would be picked up and
     delivered to the meetings, and what was to be accomplished. At these
     meetings, the participants called their project the “Chavez revolution.”
     From that point on, Chavez never lost any election. In fact, he was able
     to ensure wins for himself, his party, Congress persons and mayors from
     townships.

 14. Smartmatic’s electoral technology was called “Sistema de Gestión
     Electoral” (the “Electoral Management System”). Smartmatic was a
     pioneer in this area of computing systems. Their system provided for
     transmission of voting data over the internet to a computerized central
     tabulating center. The voting machines themselves had a digital display,
     fingerprint recognition feature to identify the voter, and printed out the
     voter’s ballot. The voter’s thumbprint was linked to a computerized record
     of that voter’s identity. Smartmatic created and operated the entire
     system.

 15. Chavez was most insistent that Smartmatic design the system in a way
     that the system could change the vote of each voter without being
     detected. He wanted the software itself to function in such a manner that
     if the voter were to place their thumb print or fingerprint on a scanner,
     then the thumbprint would be tied to a record of the voter’s name and
     identity as having voted, but that voter would not tracked to the changed
     vote. He made it clear that the system would have to be setup to not leave
     any evidence of the changed vote for a specific voter and that there would
     be no evidence to show and nothing to contradict that the name or the
     fingerprint or thumb print was going with a changed vote. Smartmatic
     agreed to create such a system and produced the software and hardware
     that accomplished that result for President Chavez.

 16. After the Smartmatic Electoral Management System was put in place, I
     closely observed several elections where the results were manipulated
     using Smartmatic software. One such election was in December 2006
     when Chavez was running against Rosales. Chavez won with a landslide
     over Manuel Rosales - a margin of nearly 6 million votes for Chavez versus
     3.7 million for Rosales.

 17. On April 14, 2013, I witnessed another Venezuelan national election in
     which the Smartmatic Electoral Management System was used to
     manipulate and change the results for the person to succeed Hugo Chávez

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Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.80 Filed 11/25/20 Page 5 of 8 as President. In that election, Nicolás Maduro ran against Capriles Radonsky. Inside that location was a control room in which there were multiple digital display screens – TV screens – for results of voting in each state in Venezuela. The actual voting results were fed into that room and onto the displays over an internet feed, which was connected to a sophisticated computer system created by Smartmatic. People in that room were able to see in “real time” whether the vote that came through the electronic voting system was in their favor or against them. If one looked at any particular screen, they could determine that the vote from any specific area or as a national total was going against either candidate. Persons controlling the vote tabulation computer had the ability to change the reporting of votes by moving votes from one candidate to another by using the Smartmatic software.

 18. By two o'clock in the afternoon on that election day Capriles Radonsky
     was ahead of Nicolás Maduro by two million votes. When Maduro and his
     supporters realized the size of Radonsky’s lead they were worried that
     they were in a crisis mode and would lose the election. The Smartmatic
     machines used for voting in each state were connected to the internet and
     reported their information over the internet to the Caracas control center
     in real-time. So, the decision was made to reset the entire system.
     Maduro’s and his supporters ordered the network controllers to take the
     internet itself offline in practically all parts in Venezuela and to change
     the results.

 19. It took the voting system operators approximately two hours to make the
     adjustments in the vote from Radonsky to Maduro. Then, when they
     turned the internet back on and the on-line reporting was up and running
     again, they checked each screen state by state to be certain where they
     could see that each vote was changed in favor of Nicholas Maduro. At that
     moment the Smartmatic system changed votes that were for Capriles
     Radonsky to Maduro. By the time the system operators finish, they had
     achieved a convincing, but narrow victory of 200,000 votes for Maduro.

 20. After Smartmatic created the voting system President Chavez wanted, he
     exported the software and system all over Latin America. It was sent to
     Bolivia, Nicaragua, Argentina, Ecuador, and Chile – countries that were
     in alliance with President Chavez. This was a group of leaders who
     wanted to be able to guarantee they maintained power in their countries.
     When Chavez died, Smartmatic was in a position of being the only

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     company that could guarantee results in Venezuelan elections for the
     party in power.

 21. I want to point out that the software and fundamental design of the
     electronic electoral system and software of Dominion and other election
     tabulating companies relies upon software that is a descendant of the
     Smartmatic Electoral Management System. In short, the Smartmatic
     software is in the DNA of every vote tabulating company’s software and
     system.

 22. Dominion is one of three major companies that tabulates votes in the
     United States. Dominion uses the same methods and fundamentally same
     software design for the storage, transfer and computation of voter
     identification data and voting data. Dominion and Smartmatic did
     business together. The software, hardware and system have the same
     fundamental flaws which allow multiple opportunities to corrupt the data
     and mask the process in a way that the average person cannot detect any
     fraud or manipulation. The fact that the voting machine displays a voting
     result that the voter intends and then prints out a paper ballot which
     reflects that change does not matter. It is the software that counts the
     digitized vote and reports the results. The software itself is the one that
     changes the information electronically to the result that the operator of
     the software and vote counting system intends to produce that counts.
     That’s how it is done. So the software, the software itself configures the
     vote and voting result -- changing the selection made by the voter. The
     software decides the result regardless of what the voter votes.

 23. All of the computer controlled voting tabulation is done in a closed
     environment so that the voter and any observer cannot detect what is
     taking place unless there is a malfunction or other event which causes the
     observer to question the process. I saw first-hand that the manipulation
     and changing of votes can be done in real-time at the secret counting
     center which existed in Caracas, Venezuela. For me it was something
     very surprising and disturbing. I was in awe because I had never been
     present to actually see it occur and I saw it happen. So, I learned first-
     hand that it doesn’t matter what the voter decides or what the paper
     ballot says. It’s the software operator and the software that decides what
     counts – not the voter.

 24. If one questions the reliability of my observations, they only have to read
     the words of
                                                                a time period in

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Case 2:20-cv-13134-LVP-RSW ECF No. 1-1, PageID.82 Filed 11/25/20 Page 7 of 8 which Smartmatic had possession of all the votes and the voting, the votes themselves and the voting information at their disposition in Venezuela.

                 he was assuring that the voting system implemented or used
       by Smartmatic was completely secure, that it could not be compromised,
       was not able to be altered.

 25. But later, in 2017 when there were elections where Maduro was running
     and elections for legislators in Venezuela,           and Smartmatic broke
     their secrecy pact with the government of Venezuela. 

( redactions/spaces changed so it would fit. The rest of 25. and later cut off...)