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I'm not exactly sure how to answer your question, but what he was saying, which was not about location at this particular moment, was that because QT deleted all texts from JC from his phone, and he has AT&T, they would not be able to access the content of any texts between QT and JC. BUT, JC had Verizon, and Verizon WILL provide (with a subpoena) the content of texts (deleted or not) for the last 7 days. So, they were able to get a report from Verizon that details all texts on JC's phone from roughly the last 7 days of her life. Hope this makes sense. We have not heard the content of those texts yet.
Wireless providers' current SMS retention policies vary. An internal Justice Department document (PDF) that the ACLU obtained through the Freedom of Information Act shows that, as of 2010, AT&T, T-Mobile, and Sprint did not store the contents of text messages. Verizon did for up to five days, a change from its earlier no-logs-at-all position, and Virgin Mobile kept them for 90 days.
They are talking about all message contents -- not deleted messages. Telco has no way of knowing what you deleted.
I would avoid VERIZON at all costs!
I'm going to disagree with you. I believe he said you CAN (or least could, in 2014) get the content of deleted messages with Verizon. And by "you" I mean LE with a subpoena.