EXAMINATION UNDER OATH OF CONFIDENTIAL W ITNESS
DATE:September 18, 2025
TIME:Commenced at 10:33 a.m. Concluded at 11:36 a.m.
Pages 1 through 31
Stenographically Reported By:
Teresa R. Cr uise, CRR, RPR, FPR-C, FPR
Registered Profe ssional Reporter
Florida Professi onal Reporter
Notary Public, St ate of Florida
Colorado
Jason
The examination under oath of CON FIDENTIAL WITNESS was taken on Thursday, September 18, 2025, commencing at 1 0:33 a.m. Said examination under oath was reported by Teresa R. Cruise , CRR, RPR, FPR-C, FPR Notary Public, S tate of Florida at Large.
(The witness, havi ng already presented their governm ent-issued iden tification and their identity verified, was sw orn in as follows.)
THE STENOGRAPHE R: Mr. Vega , could you please raise your right hand?
Do you solemnly swear to truly and accurately in terpret from English to Spanish and Spanish to English the questions propou nded and the answers given, and that you hav e such the a bility to do so?
THE INTERPRETER : I swear and I swear that I have d one so to this point this morning.
THEREUPON, JOSE VEGA, the interprete r, was sworn to tr uly and correctly
translate English into Spanish and Spanish into English.
THE STENOGRAPHE R: Mr. Vega , would you please ask our deponent to r aise his right hand?
Do you swear or af firm the testimony you're about to giv e will be th e truth, the whole truth, and nothing but the truth, so help you God?
THE WITNESS: Yes, I do.
THE STENOGRAPHE R: You c an put your hand down.
THE VIDEOGRA PHER: Here begins the examination unde r oath of a confidential witness.
Today's date is Se ptember 18, 2025. The time is 10:33 a.m.
Would counsel p lease introduce themselves for the record?
MR. CASE: My name is John case. I'm a lawyer representi ng Tina Peters. I'm investigating whether foreign agents manipulated com puter voting systems in U.S. elections.
THEREUPON:
THE VIDEOGRA PHER: You may proceed.
CONFIDENTIAL
WITNESS, having been first duly sworn, wa s examined and testified as follows: EXAMINATION
BY MR. CASE:
Q. Sir, do you have p ersonal knowledge, whether the elec tion systems, in the United States, the voting sy stems, can be mani pulated by foreign agents?
A. The electoral systems of the United States can be ma nipulated by fo reign agents or third parties.
Q. Sir, are you in danger, physical danger, if yo ur true identit y is known?
A. Yes.
Q. And in order to protect your safety, have you and I agreed that your identity will be redacted in the final transcript of your testimony, and that your fa ce will be disguis ed and your voice will be alter ed by technology?
A. That's correct.
Q. Have you receiv ed any money or thing of value in exchange for your test imony today?
A. No, not at all.
Q. Have you been prom ised any money or thing of value in e xchange for you r testimony today?
A. No, not at all.
Q. Can you tell us about your expertise in voting sys tem computers?
A. I have 20 years of experience in electoral systems. This comes from Venezuela, from 2003 onward, where we received for the time and we configured the S martmatic systems for the first time in Venezuel a. We configured the transmission systems and t he tally systems.
I was the National Coordinator for voting machines. I was the Nat ional Coordinator for national data a nd I work in th e creation of situation rooms or war rooms for t he Venezuelan -THE STENOGRAPHE R: Mr. V ega, your audio cuts out at t he end of yo ur sentence. (A discussion off the record was held.)
BY MR. CASE:
Q. You were the National Coord inator for data situation rooms or war rooms for the Venezuelan government?
A. Yes. Yes, I was t he person in charge in the situation room, for the Venezuelan government.
Q. Is the situation r oom called a war room?
A. That is correct.
Q. Who is prese nt in the war room during an election?
A. The president of the republ ic, the vice president, they could e ither be there in person or via call. The main m inisters for the country are ther e, and the pres ident of congress or what is called t he National Assembly.
In the specific ca se of Venezuela, it would be Diosdad o Cabello, Jorge Rodriguez, Delci Rodriguez, Rafael Ramirez as the president of the oil industry. H igh level milit ary personnel.
Those are the ones that are in these situation rooms or war room.
Q. And were you personally presen t in the Venezuelan war r oom with the peopl e you just named during elections in Venezuela?
A. I work together wi th them from 2004 to 2016.
Q. And when was the l ast time that you
were in the w ar room in Vene zuela during an election? What year was that?
A. 2015.
Q. Briefly describe y our expertise in computer t echnology.
A. Well, my high school degree is IT degree, that's h ow we call it in Venezuela.
Aside from that, I went to the university to st udy telecommunicat ions, even though I didn't end up graduating on t hat, I studied telecommunica tion, business creation and journalism.
I am knowledgea ble regarding programming syst ems, operating sys tems, such as Windows and Linu x, and in telec ommunications in general to be able to transm it the votes.
Q. What were you resp onsible for doing in Venezuelan elect ions between 20 03 and 2016?
A. I was responsible for configuring the voting equipment . I was res ponsible for configuring t he electoral ma nager system, responsible f or the transmis sion systems, responsible f or the electoral s ystem audits , along with the Carter center and the European Union.
On top of that, I was, after that,
responsible for the data centers, where we keep all the information of the voter recor ds, biometric systems and t he electoral syste ms before an election day.
THE INTERPRETER: Sorry, Counselor, this is the interpreter.
The interpreter was somewha t unclear in the last a nswer of the wi tness, whether he meant the election systems w here we keep the election sys tems that we re used during election days, p rior election days or to be used for futu re election days.
MR. CASE: Can you ask him that, please?
THE WITNESS: I me ant the general system, the g eneral system w here you keep the backups f or prior elections and where you would set up future e lections.
So, in the case of Venezuela, the center is centralized in one place. It’s very similar to what is done here in the United States ex cept for that each county has its own s ystem and they operate very much indep endently.
In Latin America, our countries have
just a single voting system, and the United States has over 3,000.
BY MR. CASE:
Q. Are you familiar with a ministry in Venezuela called the National E lectoral Council?
A. Yes, I was an empl oyee of the National Electoral Council.
Q. And was it as an employee of the National Elec toral Council t hat you set up the war room to manag e the elections in Venezuela?
A. That is correct.
Q. Did you also set up or direct others under your super vision to set up situation rooms in the states throu ghout Venezuela?
A. Correct. We would create manuals so they can replica te the rooms, and then send over the data to t he main room.
Q. So each state in V enezuela had its own situation room w here election d ata would be transmitted to the war room; is that correct?
A. That's correct. Each individual monitors his sta te and then sends over the studies to the main room.
That's why I have the minister for the administration in each one of t he different rooms
because each min ister is responsible for a certain number of states in the country.
Q. Were the results of elections manipulated in V enezuela while you worked for the National Elec toral Council?
A. That is correct.
Q. And how were election results manipulated?
A. In the case of 2004, one million fake voters were i nputted into the system, into the record of voters, a nd then the electo ral system was used in order to designate who each citizen had voted for.
THE INTERPRETER: Sorry, the interpreter would like to make a correction.
"And the electo ral system w as used to determine who each citizen h ad voted for that the gove rnment later on used to be able to persecute t hose that were not within its ranks."
THE WITNESS: In 2006, a tool was used. The to ol was called S-A-E-S data utel.
BY MR. CASE:
Q. Can you explain how SAES works?
A. SAES data ut el is a tool that allows you to do a gene ral test of the entire electoral system.
In order for you to test the entire system, you need to input the c redentials or the certifications for the parti cularly elec tion. And this tool allows you to emulate voting machines in order to then tr ansmit the votes.
Q. Was SAES used in Venezuela to manipulate the outcome of elections? So change the results?
A. It was used by the technology directors. In this case, his name is Eduardo Hernandez. Later on it was used by D elci's cousin, his name is Loui s Campos Cabello.
Q. And how did the y use SAES to manipulate Venez uelan elections?
A. By using a statistica l system, knowing the electors behavi or, without exceed ing a maximum of 2 or 3 percent of vote manipula tion, while at the same time ta king over a large number of voting machines that you need in order to change the total amount of votes tha t you need to modify.
So, specifically, in the year 2008, the technology director for the National Electoral Council was in charge of transmitting the data from an entire state so that his relatives could win.
And this can be co rroborated because in the transmission system, the te lephone companies have to show that all the voting machine s issue the transmissions through the of ficial chann els, and a red flag came up that -- that p articular state, that's the state of Merida, had not issued its transmission yet. So it issued a red flag in order for it to be determine d whether there was a failure or an error.
And so the n ational center of tallying, or the adjudication cent er, responded that -- that the entire state's data had already been transmitted, yet there was no traceability, no trace that showe d that state ha d transmitted the data through the regular transmiss ion channels.
So, the solution w as to have all the different pieces of equipment r etransmitted. But, nevertheless, th at would not ch ange the final tally, because t he tally was alrea dy there -- the total was alread y there, and al l the technical reports regardin g these errors or failures were
handed over to t he military personnel.
So they used SAES data util ity tool to transmit the ent ire information for the entire state because you can use it to transmit correctly all the st ate's data.
This is supposed to be a tool that -for its normal u sage, it’s supp osed to allow you to test the inte grity of the syste m. When it’s misused, it can allow you to injec t votes without people knowing you did so.
Q. And can you tell us what S-A-E-S stands for?
A. System automated e lectoral systems -is it system?
It’s automat ed system of elections or -- or something similar. It’s like a centralized elec toral system. It stands for automated system of elections or something like that.
That is -- that is -- appli es for the entire line of products from the Smartmatic company. Every pro duct is called SAES. So, in Venezuela, we ha d SAES 3000, 33 00, SAES 4000.
And in the United States, they used SAES 3367, fo r the Chicago, Ill inois machine, where
President Obama, in the 2006 elections, cast his vote.
Q. Is there a data ut ility feature for S-A-E-S?
A. So there's a tool -- aside from the system itself, there's a too l called SAES data UTEL that allows y ou to test the ent ire system. In general, any co mpany providing election systems needs to have suc h a tool because they need to be abl e to prove the integrity of the system.
Q. Can the S-A-E-S da ta utility t ool be used to manipula te election results?
A. That is correct.
Q. How does tha t work?
A. So, in the case of Venez uela, this tool has been de signed for the SAE S system. So, now, if my system is integrated wi th an external system, I have to then adapt my tool to be able to test all of t he element of my system plus the element of th e other system that is being integrated wi th my system.
Well, then, this happened in 2005 when Smartmatic, of t he Venezuelan government who owns the source code, the source code b elongs to the
government, made an integration wi th the American company called S equoia Voting Syst ems when it was acquired in the year 2005 to th en bring to pass the elections -- carried out the election s in Chicago, Illinois in 2006.
That then lendi ng or selling its technology to Dominion Votin g Systems in the year 2010, meaning that I need to ha ve a tool to test the integrity of the system, and I adapt that tool to the different integrations.
So that's why I'm saying that you would adapt the tool to each on e of the systems because each system has a diffe rent way in which is writes to the da tabases and differ ent processes.
Q. Is auditing an electi on part of the Smartmatic software?
A. That is correct. And it varies by state and countr y. And, also, whe n you audit an election or when you a udit a system, you will be auditing only th at which the compa ny wants you to see or what the electoral body wan ts you to see.
In other words, it ’s not like the audit is like an open audit, on ly the modules and the functions that the publi c needs to know are audited.
That is why you have been unable to detect whether a library has been hidden, has been locked or if it can be manipulated, a nd you are not auditing tools l ike this one eithe r, like SAES data utility, which a re tools that allo w you to inject votes.
So people ends up not knowing what the tool's actual purpose or utility is.
Q. So if an audit discov ers a problem, was there a strateg y of how to explai n that to the public?
A. No, because you would never show the public the error s of the system , you would only show the functio nality of it.
It was only in 2004 that it was uncovered, th at you could find out who people voted for; and, by 200 5, there was a mod ification made, but that was the only thing.
Q. What was -- what w as the role of human error in terms of public rel ations?
How did human erro r figure into the public relations of Smartmatic?
A. When any company -- and that doesn't just apply to Smartmatic -- whe n any company mentions human error, what you' re doing is you're
putting the resp onsibility for the blame on a person, and n ot on the syste m itself.
It’s easier for me to fire somebody from a company a nd then pay them their severance package as co mpared to me losin g my entire business because my elect oral system, or the system that I am selling has errors. I would end up losing everything.
That's why you can read up how all these different electoral companie s, they're always alleging human e rrors here and there. Therefore, for any type of manipulations of elections, you need to have the company to pro vide the certs because they are the ones who k now how their own system works.
They know how to make an injection into the syst em in an undetectable manner, so that when a detailed aud it of the election is performed it wouldn't show an y sort of trace.
Q. Is this S-A-E-S da ta utility similar in its security to a key to a house?
A. That is correct.
Q. Can you explain?
A. This tool allows you to emulate a voting machine.
It allows you to emulate multiple voting machines, which means th at I can transmit on behalf of a mach ine, as if I was t hat machine. The original machine is not transmi tting, but I'm emulating this m achine, and I'm transmitting whatever data I need to transmit.
In the case of Venezu ela, the machines that would be transmitted, t he data to the machines that would trans mitted were the ma chines that were not going to be audited.
Q. So, in the case of Venezuela, was the S-A-E-S data utility used to transmit fictitious votes?
A. That is correct. That's the function for which the Ve nezuelan government would use that tool for.
Q. How was the Venezu elan government involved in deve loping the Smartma tic software that was used to run Ven ezuelan elections?
A. Their involvement was a hundred percent. The software was c reated by the Venezuelan go vernment. Histori cally speaki ng, the government fi nanced Smartmat ic for it to create the software.
This is obvious and public
information, based on the audits that the European Union did of the elections of 2 004, where its president -- the pr esident of Smar tmatic, Antonio Mugica, he infor med the European Union that the source code was property of the Na tional Electoral Council.
Q. What is the con nection between Dominion Voting Systems, Sequoia V oting Systems and Smartmatic?
How are those thre e entities related?
A. So Smartmatic purc hases Sequoia in 2005, so the SAE S software is i mplemented for the element of Sequoia.
From 2007 to 20 13, Sequoia and Dominion work ed for the e lections in the Philippines. And that relation ship allo ws Dominion to purchase Sequ oia in 2010, al lowed it to purchase Sequoia in 2010.
So, therefore, the SAES election software from Smartmatic ended up being implemented in Sequoia and later on transferred to Dominion. And you have two engineers ther e, their names are David Moreno and Ronald Morales, w hich are -- which were the ones that handled the integration of the software belongi ng to Smartmatic c alled SAES and
integrated it into Sequoia.
And then these very same en gineers did the integration from Sequoia to Do minion in the year 2010. Curr ently, these engin eers still work for Dominion and they are in ch arge of their software.
Q. Where is the wo rldwide global headquarters for Dominion Voting Systems, Inc.?
A. They have three headquarter s, United States, Canada a nd Belgrade, Serbia.
It is in Serbia th at they developed the programs that a re then impl emented here in the United States. Ronald Morales is the person in charge of configuri ng the entire s ecurity network so that these three different head quarters can communicate between th emselves.
At that point in time, they used initially VPN networks. And, d uring the days that the American electi ons were held, Ser bia is the office that is r esponsible f or resolving the errors that pop up in the systems.
Q. Is it possible for engineers in Serbia, worki ng for Dominion Vo ting Systems, to inject votes into an election in t he United States of America?
A. Though I don't have evidence of that, it is possible. If I happen to have access , remote access to the syste m, I can make c hanges in the electoral system.
Q. And would that be by using the S-A-E-S data ut ility tool?
A. No.
Q. And then how would it be done?
A. Well, we need to unde rstand so mething. Let's not, you know, end up mar rying this tool name, but rat her its func tionality.
So what this tool does, SAES data utility, it uses the l ibraries for th e electoral system that were first used in Venezuela then transferred over to Sequoia and then finally to Dominion.
It uses system vot es or errors -let's call it the libraries. The librar ies for data transmissio n, data encryption by libraries, the communication between the databases.
So what SAES data utility d oes is that it takes the credentials or passwo rds for an election so that the s ystem can autho rize it to connect itsel f, and then it can inject as many votes as it needs to.
If the Dominion systems have bugs in their libraries, then, in turn, yo u can you can use those bugs while having the correc t credentials or passwords, and u se the processes of the same system to then inject the votes that are needed, whether it be minutes, d ata or votes.
Whatever that t he system allows me to do, I will be able to do it while using those libraries.
Q. Did you revi ew the forensic image of the Mesa County election management server from the November 2020 election?
A. I did.
Q. And what did you find in your examination of that forensic image?
A. That the ele ctoral syste ms of Dominion have vulnerabili ties that can be u sed to attack the system. It’s so urce code is no t a hundred percent obfuscated, or hidden.
The use in hand ling passwords -they're all s tored in plain text, which allows you to get that data from the datab ase. You can get it from the backups of the differe nt elections , from the settings files of an ele ction, and from the button device that allows to ha ve access to the
equipment, be cause the crede ntials are a lso stored in the but ton itself.
So, once you have that information, and if you know how the system ope rates, then you can attack the encryption le vers, which then literally allows you to manipulate the system and change votes at will.
Additionally, on top of that, the Windows Operating S ystem has, in turn, vulnerabilities and can also be attacked using an error code, it’s called the intern al blue. It’s an attack system th at even the entity the NSA uses here in the United States.
Q. Now, after the 202 0 election, we were told by the Atto rney General of the United States that the 2020 election was t he most secure in history.
We were also told by the Colorado Secretary of State that the Colorado voting system was the gold sta ndard for runni ng elections.
Can you tell us if that is true? Are our elections in the United States and Colorado really secure?
A. No, they are not secure.
Q. Can any election be run fairly and
securely using Dominion soft ware, which is so susceptible to manipulation?
A. Well, we have to k eep in mind or understand somet hing clearly: No system is infallible.
Dominion's software is a software that has a lot of errors or bugs. A nd they have -they've had many years to corre ct them and they haven't done so. From an IT st andpoint, yo u could even say that th e types of erro rs that they have made are very basic. But the reason why those errors are inten tionally there is bec ause they need it, they n eed them.
Now, can they be cure d in the future?
Of course they can. Is it possibl e that you can have a secure election using electronic voting systems in the future of the Unite d States? Of course.
But the current vo ting -- the current software that Do minion Voting Syst ems is using right now does not provide the -- cannot ensure that an election cannot be manipul ated because if we, not knowing how their system w orked, were able to detect the bugs, that means that either an engineer or a technician working for Dominion that
have even better knowledge than we have, can use his or her system to manipulate the votes as needed.
And it can be d one indetectably -without be detected.
Q. Have you unders tood all of my questions as tra nslated by t he interpreter?
A. That is correct.
Q. Did you answer all questions truthfully?
A. Totally t ruthfully.
Q. Were your answe rs based on your personal k nowledge?
A. Totally.
Q. Okay. You have another appointment and you have to interrupt th is to go to that appointment?
A. Yes, as I told you earlier when we first started.
Q. Would you come bac k later this afternoon, please?
A. Yes.
As soon as I'm done with my other appointment, I can come back an d we can continue this co nversation.
THE VIDEOGRAPHER: Thee time is 11:35 a.m.
We are going off the video record. (The examination u nder oath was adjourned at 11:35 a.m.)
THE STATE OF FLORIDA
COUNTY OF PASCO
I, Tere sa R. Cruise, Nota ry Public, State of Florida, c ertify that JOSE VEGA remotely appeared before me on the 18th of September, 2025, and was duly sworn.
Signed this 18th day of Sept ember, 2025.
T ERESA R. CRUISE, C RR, RPR, FPR-C
Notary Public - St ate of Florida
Commission Numb er: HH351124
Expiration Date : 02/25/2027
CERTIFICATE
THE STATE OF FLORIDA
COUNTY OF PASCO
I, Tere sa R. Cruise, Nota ry Public, State of Florida, certify that CONFIDENT IAL WITNESS personally ap peared before me on the 18th of September, 20 25, and was duly sworn.
Signed this 18th day of Sept ember, 2025.
T ERESA R. CRUISE, C RR, RPR, FPR-C
Notary Public - St ate of Florida Commission Numb er: HH351124
Expiration Date : 02/25/2027
THE STATE OF FLORIDA COUNTY OF PASCO
I, Teresa R. Cruise , a Certified Shorthand Report er, do hereb y certify:
That I was authori zed to and did stenographically report the forego ing examination under oath of CONFIDENTIAL W ITNESS, pages 1 through 31, that a review of the transcrip t was not requested, and that the t ranscript is a true record of my sten ographic notes.
I furth er certify that I am not a relative, employ ee, attorney, or c ounsel of any of the parties, nor am I a relative or employee of any of the parties' att orneys or couns el connected with the action, nor am I financially inte rested in the action.
The foregoing certi fication of this transcript do es not apply to any repr oduction of the same by a ny means unless un der the direct control and/o r direction of the certifying reporter.
DATED this 18 th day of Se ptember, 2025.
T ERESA R. CRUISE, C RR, RPR, FPR-C