Established Fact
On September 18, 2025, attorney John Case — representing Tina Peters in Case No. 1:25-cv-00425-STV before the U.S. District Court for the District of Colorado — took the sworn examination under oath of a confidential witness whose identity has been redacted, face disguised, and voice altered by technology due to confirmed physical danger to the witness. The examination was conducted in two sessions (AM: 10:33 a.m.–11:36 a.m.; PM: 2:24 p.m.–4:55 p.m.) and transcribed by certified court reporter Teresa R. Cruise. An interpreter, Jose Vega, translated English–Spanish throughout.
The witness testified to 20 years of direct personal experience in Venezuelan electoral systems starting in 2003, serving as:
National Coordinator for Voting Machines for the Venezuelan government
National Coordinator for National Data
Person in charge of the situation room (“war room”) during Venezuelan elections from 2004 to 2016
Responsible for configuring Smartmatic systems, transmission systems, tally systems, and electoral audits conducted alongside the Carter Center and the European Union
Responsible for data centers storing voter records, biometric systems, and election backups
Key Sworn Disclosures
1. U.S. Voting Systems Can Be Manipulated by Foreign Agents
The witness’s opening sworn answer: “The electoral systems of the United States can be manipulated by foreign agents or third parties.”
2. The Venezuelan War Room — Who Was Present
The witness testified to personally working in Venezuela’s election war room from 2004 to 2015, identifying those present as: President Maduro, Vice President, Diosdado Cabello, Jorge Rodríguez, Delcy Rodríguez, Rafael Ramírez (oil industry president), and high-level military personnel.
3. Smartmatic Was Created to Rig Elections — Venezuelan Government Owns the Source Code
The witness testified that Jorge Rodríguez awarded Smartmatic its founding contract in 2003 for $250,000 and a 28% ownership stake in the company. In 2004 Smartmatic received $140 million from the Venezuelan government. The source code for Smartmatic software is owned by the Venezuelan government and kept in the central bank in Caracas. The witness further testified that Jorge Rodríguez collected personal bribes from Smartmatic, and that the $40 million first-machine-purchase contract (authorized by Rodríguez) was inflated — the Italian manufacturer Olivetti publicly disclosed the real cost was $21 million, a $19 million overcharge that formed part of the kickback structure.
4. Smartmatic’s Sister Company Bizta — Both Incorporated in Delaware
The witness identified Bizta as Smartmatic’s sister company (2003–2004), with the same ownership principals. Both companies were incorporated in the state of Delaware.
5. Sequoia Acquisition Chain: Venezuelan Money → American Voting Market
Smartmatic acquired Sequoia Voting Systems in 2005 (its first year of corporate existence) for $17 million — using Venezuelan government funds. Sequoia held 20% of the U.S. voting market at acquisition. Dominion Voting Systems then acquired Sequoia from Smartmatic in 2010.
6. Voting Hardware Manufactured in China and Taiwan — Firmware Pre-Installed
The witness testified that Smartmatic/Dominion voting equipment components were manufactured in China and Taiwan, with firmware pre-installed at the factory. The critical technical disclosure: voting machine computers contain internal modems capable of internet communication, and it is the responsibility of each corporation to disable those modems. When asked whether firmware could keep a modem active even when software commands it to be disabled — i.e., the modem stays on while the software reports it as “off” — the witness answered: “Yes… the answer to your question is yes.”
7. Cuban Officials Embedded in Venezuelan Government Operations
The witness testified that Cuban officials held “full oversight” of Venezuelan government activities and that Cuban engineers received training in Venezuela on electoral technology, biometrics, passport systems, and telecommunications/intelligence systems.
Citations
Confidential Witness. Examination Under Oath. Peters v. [Respondent], Case No. 1:25-cv-00425-STV. U.S. District Court, District of Colorado. Filed September 23, 2025. Stenographically reported by Teresa R. Cruise, CRR, RPR, FPR-C, FPR., AM Testimony https://electioncrimebureau.com/wp-content/uploads/2026/06/100-AM_Transcript_of_EUO_Confidential_Witness.pdf , PM Testimony https://electioncrimebureau.com/wp-content/uploads/2026/06/101-PM_Transcript_of_EUO_Confidential_Witness.pdf