"Pings" in this context are not incoming calls/texts, scheduled updates, nor are they internally generated events that awakened the phone.
"Pings" in this context refers to a signal sent by a cellular provider for the purpose of trying to locate a specific phone, initiated after law enforcement contacts a cellular provider (AT&T, T-Mobile, Sprint, Verizon) and asks that provider to help find that given phone's location.
The provider then sends out a signal from its tower(s) with the express purpose and intention to try to locate that phone's location. Based on different techniques and data (like triangulation and time-on-arrival), the cellular provider can then infer certain information about that phone's present location and provide that information to Law Enforcement.
These services from cellular providers intended to assist Law Enforcement are called "Location Based Services".
That is what is being referred to when this motion discusses "pings". This is not just texts and missed calls.
This process is initiated at the behest of law enforcement, and conducted specifically by the network carrier.
View attachment 500553
The table above is from the FBI's Cellular Analysis Survey Team (CAST) unclassified Cellular Analysis & Geo-Location Field Resource Guide.
In this instance, the provider LE contacted was AT&T.
From that same Field Resource Guide:
"AT&T — Mobile Locate: Triangulated coordinates of device based on Timing Advance or Time on Arrival (TOA) and suspected radius e mailed every 15 30 min. Use event based mobile locate."
Source — FBI's Cellular Analysis Survey Team (CAST) unclassified Cellular Analysis & Geo-Location Field Resource Guide
Link to Source —
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That's why the motion filed today specifically mentioned the 15 minute interval of these "pings".
If they were incoming calls/text, scheduled updates, or internally generated events, these would not correspond to a 15 minute interval. Instead, if what you're suggesting is true, these events would be more clustered together in their timing, and not spread out evenly across 15 minute intervals.
So these are not just random text messages. These are not just random calls. These are not just random app updates. This is not a cellphone only weakly connecting to a tower with a flakey connection strength.
The filing today suggests the phone was consistently "pinged" by the provider in 15 minute intervals, until for some reason, the provider and law enforcement no longer received any information back from these "pings". This missing gap in the location-based service data suggests that the phone was either 1) physically at a location far beyond the reach of the provider's location based service signal, or 2) the phone was powered off, then much later powered back on.
In either event, it blows up the State's timeline.