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.