John Wotton, AVIS Budget Group

He works at Avis Budget Group.

Exhibit 239 lists a rental truck’s unique number.
He has been with Avis budget for 26 years and is now a corporate security manager. He has been for two years.
He has been in a security function role for the last ten years.
They have GPS devices on vehicles, not to track every rental customer but for tracking missing, abandoned, or stolen vehicles.
Accessing this information is part of his job responsibility.
Exhibit 292 is a printed report from AirIQ on a specific rental truck.
If they are not actively tracking a vehicle, there are 4 historical pings a day - 6 AM, noon, 6PM, and midnight.
The production order for records listed any documents associated with Letecia Stauch’s name.
The first line of the report was a “power up” which happens every twenty-five hours.
This GPS is in Eastern Time.
6:10 AM is one of the four scheduled daily historical pings.
12:10 PM on February 1st 2020 (10:10 AM MT) the vehicle was Love’s Truck Stop in Pueblo, CO.
At 4 PM MT the car was on US 87 in Texas.
At 10 PM MT it is in Amarillo, Texas at 18 West Plaza Drive. It remained there until February 2nd, 2020 at 10 AM MT.
At 4:10 PM the car is in Bellevue, Texas.
At 10 PM the car is at 601 West Thompson Street in Decatur, Texas.
On February 3rd, 2020 at 2:14 AM there is a ping. It was still at 601 W. Thompson.
4 AM the car is still there.
At 10 AM the car is moving at 29 kilometers per hour in Decatur, TX.
On February 3rd 2020 at 4:10 PM the car was on I-20 in Rustin, Louisiana; moving at 115 kilometers per hour.
At 10:10 PM, the car is at 29451 US Highway 98 in Dauphin AL, moving at 40 kilometers per hour.
On February 4th, 2020 at 3:15 AM the car was in Ferry Pass, Florida. The vehicle is stopped.
Now in Eastern Time.
6:10 AM 8080 North Davis Highway in Ferry Pass; vehicle is stopped. Still there at 12:10 PM.
At 6:10 PM it is at 8818 Churchill Way Southwest in Lake City, FL; it’s moving 119 kilometers per hour.
On February 5th, 2020 at 12:10 AM the car is at 13028 Plantation Park Circle, Lake Buena Vista, FL. The vehicle is stopped.
It is still there and stopped at 6:10 AM and 12:10 AM.
It does not move until February 6th 2020.
On February 6th 2020 at 12:10 AM the car is moving 119 kilometers per hour I-95 in Pooler, GA.
At 6:10 AM the car is at Days Inn in ForestBrook South Carolina. The vehicle is stopped.
At ∫ the car is at 2246 Highway 501 East in Conway, South Carolina; moving very slowly 7.2 kilometers per hour.
At 6:10 PM the car is at 1400 Cannon Road in Myrtle Beach, South Carolina.
The vehicle is stopped and stays there until February 12th, 2020 at 12:10 PM when it goes to Old Town Road in Garden City South Carolina moving 97 kilometers per hour. It moves through various locations in South Carolina. This is a budget truck location.
The rental contract was from February 1st to February 6th.
The car ultimately ended up in Rhode Island at a different Budget location.
These data points are used by the loss prevention team to track down vehicles.
With the historical data you can potentially map someone’s movements and vehicle location.

He works at Avis Budget Group.

Exhibit 239 lists a rental truck’s unique number.

He has been with Avis budget for 26 years and is now a corporate security manager. He has been for two years.

He has been in a security function role for the last ten years.

They have GPS devices on vehicles, not to track every rental customer but for tracking missing, abandoned, or stolen vehicles.

Accessing this information is part of his job responsibility.

Exhibit 292 is a printed report from AirIQ on a specific rental truck.

If they are not actively tracking a vehicle, there are 4 historical pings a day - 6 AM, noon, 6PM, and midnight.

The production order for records listed any documents associated with Letecia Stauch’s name.

The first line of the report was a “power up” which happens every twenty-five hours.

This GPS is in Eastern Time.

6:10 AM is one of the four scheduled daily historical pings.

12:10 PM on February 1st 2020 (10:10 AM MT) the vehicle was Love’s Truck Stop in Pueblo, CO.

At 4 PM MT the car was on US 87 in Texas.

At 10 PM MT it is in Amarillo, Texas at 18 West Plaza Drive. It remained there until February 2nd, 2020 at 10 AM MT.

At 4:10 PM the car is in Bellevue, Texas.

At 10 PM the car is at 601 West Thompson Street in Decatur, Texas.

On February 3rd, 2020 at 2:14 AM there is a ping. It was still at 601 W. Thompson.

4 AM the car is still there.

At 10 AM the car is moving at 29 kilometers per hour in Decatur, TX.

On February 3rd 2020 at 4:10 PM the car was on I-20 in Rustin, Louisiana; moving at 115 kilometers per hour.

At 10:10 PM, the car is at 29451 US Highway 98 in Dauphin AL, moving at 40 kilometers per hour.

On February 4th, 2020 at 3:15 AM the car was in Ferry Pass, Florida. The vehicle is stopped.

Now in Eastern Time.

6:10 AM 8080 North Davis Highway in Ferry Pass; vehicle is stopped. Still there at 12:10 PM.

At 6:10 PM it is at 8818 Churchill Way Southwest in Lake City, FL; it’s moving 119 kilometers per hour.

On February 5th, 2020 at 12:10 AM the car is at 13028 Plantation Park Circle, Lake Buena Vista, FL. The vehicle is stopped.

It is still there and stopped at 6:10 AM and 12:10 AM.

It does not move until February 6th 2020.

On February 6th 2020 at 12:10 AM the car is moving 119 kilometers per hour I-95 in Pooler, GA.

At 6:10 AM the car is at Days Inn in ForestBrook South Carolina. The vehicle is stopped.

At ∫ the car is at 2246 Highway 501 East in Conway, South Carolina; moving very slowly 7.2 kilometers per hour.

At 6:10 PM the car is at 1400 Cannon Road in Myrtle Beach, South Carolina.

The vehicle is stopped and stays there until February 12th, 2020 at 12:10 PM when it goes to Old Town Road in Garden City South Carolina moving 97 kilometers per hour. It moves through various locations in South Carolina. This is a budget truck location.

The rental contract was from February 1st to February 6th.

The car ultimately ended up in Rhode Island at a different Budget location.

These data points are used by the loss prevention team to track down vehicles.

With the historical data you can potentially map someone’s movements and vehicle location.