Subpoena The Rental Agreements — The Reachable Half Of The Vehicle Question

:::caution Legal Disclaimer Tyler Robinson is charged, not convicted, and is presumed innocent. Nothing on this page states as fact that any living person committed a crime, destroyed evidence, or acted improperly. Court filings in this case are subject to a gag order and sealing, so the public record is incomplete by design. :::

The One Thing We Would Do Differently

Serve a subpoena duces tecum on every car rental company operating at or near Provo Municipal Airport and Salt Lake City International, for every agreement opened or closed in the September 2025 window, and get the telematics before it ages out.

This is the most reachable instrument in the entire aircraft-and-ground-vehicles cluster, and that is the argument for doing it first. A subpoena duces tecum to a rental company is an ordinary civil-practice document. Utah state courts issue thousands of them a year, to hospitals, banks, employers and phone carriers. It requires no federal agency to waive anything. It reaches no classified holding. It asks no court to decide a constitutional question. A clerk issues it and a records department answers it.

Compare that to everything else in this cluster. Aircraft ownership behind a foreign registry is opaque. Federal flight data must be authenticated by somebody who will not come. An intelligence holding is unreachable in practice. But the ground leg — who collected a car, on whose licence, on whose card, and where that car then drove — sits in a commercial database owned by a private company with a legal department that answers subpoenas as routine business.

That ground leg is the open question this site has never been able to close. The rental cars and vehicle movements timeline records the allegation, surfaced by Candace Owens, that rental cars were issued to unidentified passengers off the Egyptian-registered aircraft at Provo Municipal Airport — and records equally that Duncan Aviation, the maintenance facility named in those threads, is not documented as offering car rental at all. So the issuing party is unknown. A subpoena is exactly the tool that turns an unknown issuing party into a named one, or shows that no such rental exists.

The rider

This is the attachment, not a description of one. It is drafted to a records custodian, and each paragraph is written so a records department can run it as a query.

Every rental agreement opened, closed, extended or cancelled at any location within twenty-five miles of Provo Municipal Airport (PVU), and at every Salt Lake City International (SLC) concession counter, between 26 May and 3 June 2025 and between 3 September and 12 September 2025 — produced by agreement number, with the open and close date and time stamped to the minute.
For each agreement, the renter application and the renter profile: full name as given, address as given, telephone, email, loyalty or corporate account number, and the corporate account or billing code if the rental was placed against one.
The driver's licence or passport scan captured at the counter for the renter and for every additional authorised driver, together with the licence jurisdiction and expiry recorded in the system.
The payment instrument record: card type, issuing bank, the truncated account number as retained, the authorisation and settlement records, the billing address on file, and the identity of any third party who paid or guaranteed the rental.
The vehicle assignment record: VIN, licence plate and plate jurisdiction, make, model, model year, colour, and any window tint, livery or aftermarket modification noted on the unit record.
Odometer out and odometer in, fuel out and fuel in, and the computed mileage total for each agreement.
The GPS or telematics track for each assigned unit across the rental period — every recorded position, timestamp, speed and ignition event — from the fleet telematics provider, the OEM connected-vehicle service, or both. Produce the provider's name and the retention schedule that governs the data even where the data itself is gone.
The toll and violation record posted to the agreement, including every transponder or plate-based toll transaction billed through the company's toll partner, with the gantry location and timestamp for each, and every citation, parking notice or automated-camera notice forwarded to the renter.
The damage inspection reports at check-out and at check-in, including the photographic set, the inspecting employee, and the timestamp and any location metadata on each photograph.
The counter agent's identity for each transaction — the employee who executed the check-out and the employee who executed the check-in — so the agreement can be authenticated by a person rather than by a printout.
The reservation record behind each agreement: the booking channel (counter, telephone, website, app, corporate travel desk or third-party broker), the date and time the reservation was created, the account or profile that created it, and the originating telephone number or network address the system logged.
The unit movement history for each assigned vehicle for thirty days either side of the agreement — the immediately preceding and immediately following rentals by agreement number, and every inter-branch transfer — so a vehicle can be traced through the fleet rather than only inside one contract.
The insurance and waiver record: the loss damage waiver, supplemental liability and any corporate insurance certificate accepted in place of them, with the underwriter named.
Any incident, loss-prevention or law-enforcement contact record touching these agreements, including any request from any agency for any of these records, the date of that request, and the legal process it came under.
The records custodian declaration under Utah Rule of Evidence 902(11), executed in the form the rule requires, so the production is self-authenticating and no witness has to fly to Provo.
Where a record is not produced, the retention schedule and the deletion record that explains its absence, identified by system and by the date the item aged out.

Paragraph 14 is the one most riders leave out, and it is the paragraph that answers a question no other document can. If an agency asked this company for these records in September 2025, that request is itself a record, it is held by a private party, and it is not protected by anything the federal government can assert. Paragraph 16 is not boilerplate. It converts a "we do not have it" into a dated, signed, checkable statement, and it is the paragraph that makes the control test below possible.

Two windows are named in the rider, and each has a reason. The 3 to 12 September 2025 window covers the days the SU-BTT aircraft is reported to have sat at Provo, and it extends two days past the event because a vehicle collected before an event is returned after one. The 26 May to 3 June 2025 window covers the earlier SU-BTU visit, and it is in the rider for a specific reason: a rental in May and a rental in September under the same name, the same card, or the same corporate account is a pattern, and a pattern is admissible in a way a single transaction is not. The Egyptian crew hotel research is an attempt to reconstruct the same ground leg from the accommodation end; this is the same question asked of the company that would have handed over a key.

The gateway, and the crucial distinction

The alternative-perpetrator notice is the gateway for this cluster, and nothing on this page changes that. But the gateway governs the argument, not the gathering. A defense may lawfully collect a rental agreement long before it decides what to do with it. Nobody has to notice a third-party defense to learn who rented a car.

The order matters in exactly one direction. Use this material to argue that someone else committed the offence, and the proffer must already be before the court. Use it to show that a vehicle discussed on the police radio was never identified, and it is ordinary impeachment of the investigation — Route 2, which needs no alternative perpetrator at all. That is precisely why an attorney gathers this early: the collection is cheap and unconditional, and the decision about how to use it can wait.

What The Defense Team Did Instead

The defense in this case uses this exact instrument. On 1 April 2026 counsel filed a Notice of Subpoena Duces Tecum directed to the Utah County Sheriff's Department, giving notice under Utah Rule of Civil Procedure 45(b)(3) that the subpoena was issuing. So the mechanism is live, understood and in active use by this team. Separately, on 8 October 2025, counsel moved to preserve evidence — but that motion is directed at the Utah County Attorney's Office and the law enforcement agencies acting as its agents, not at any private company, and a preservation order aimed at the State's custody cannot reach a rental company's servers.

On the certified record we hold, exactly one vehicle is discussed. On preliminary-hearing Day 4, 9 July 2026, Sergeant Jennifer Faumuina testified on direct that she collected the defendant's car, that it was collected at his parents' home, and that it is a gray Dodge Challenger. That is the whole of it. Her cross-examination that afternoon contains no vehicle question at all. The words rental, rented and VIN appear nowhere in either the certified Day 4 or the certified Day 5 transcript.

We searched the filing archive for this instrument directly. Across the 140 filings we hold from 2025 and the 170 we hold from 2026, exactly two carry the word subpoena in their filename — the 12 January 2026 subpoena for Sergeant David Hull, and the 1 April 2026 notice to the Sheriff's Department. The tracking file records the second of those as a broken chain: neither the notice's underlying subpoena nor any return of service is held, and the same is true of the Hull subpoena. So even where we can see that a records subpoena issued, we cannot see what it asked for or what came back.

Nothing in the archive we hold requests a rental agreement from anyone. That is a statement about our material and about nothing else. The filings in this case are subject to a gag order and are partly sealed, the archive holds 374 PDFs against 867 known docket entries, and only 258 of those entries ever had a public PDF at all.

Where This Belongs In The Case

Stage of the case	When that stage runs	Status of this step
Third-party preservation letters	Needs no court and no case number; available immediately	Not visible on the public record
Subpoena duces tecum, URCrP 14 / URCP 45	From the filing of the information onward; used in this case on 1 April 2026	No public subpoena to any rental company
Preliminary hearing cross	July 6-10, 2026 — completed	Certified Day 4 shows one vehicle line, the defendant's own car
Rule 902(11) admission and trial use	After bind-over; no trial date set	Not yet due

Witness Or Discovery Target

How it would be done	Target	Took the stand?	Status on the public record
Subpoena duces tecum under URCrP 14, noticed under URCP 45(b)(3)	Records custodians of the national rental brands with counters at, or delivering to, Provo Municipal Airport and every branch within twenty-five miles	n/a	No public subpoena to any rental company
Subpoena duces tecum	Records custodians of the Salt Lake City International rental concessionaires	n/a	Not found in the material we hold
Subpoena duces tecum	Peer-to-peer rental platform records for hosts operating near PVU and Orem	n/a	Not found in the material we hold
Out-of-state custodian certificate, Utah Code 77-21-3	Custodians at each company's out-of-state headquarters	No	The same route counsel used for Lance Twiggs; the State moved to quash that one
Cross-examination — witness testified	Sergeant Jennifer Faumuina, crime-scene sergeant	Yes — 7 and 9 July 2026	Certified Day 4: collected the defendant's gray Dodge Challenger at his parents' home; no other vehicle discussed
Records demand to a public agency	Utah County Sheriff's Department and Orem Police plate-reader returns for 10 September 2025	n/a	A subpoena duces tecum to the Sheriff issued 1 April 2026; neither the notice nor any return is public
Subpoena duces tecum to a non-party	The fixed-base operator and ground handler that met the aircraft, for any car ordered, delivered or returned on a customer's behalf	n/a	Not found in the material we hold
Subpoena duces tecum	The manufacturer's connected-vehicle service, where the fleet unit carried one and the rental company is not the custodian	n/a	Not found in the material we hold
Rule 902(11) certification	A records custodian declaration accompanying each production	n/a	Not yet due

The Questions That Were Not Asked

Addressed to Sergeant Faumuina, who testified on Day 4 and whose certified transcript we hold. The certified transcript does not show any of these lines being pursued.

Sergeant, you told the Court you collected the defendant's gray Dodge Challenger at his parents' home. How many other vehicles did this investigation collect?
Did your team obtain a rental agreement — from any company, for any vehicle — as part of this investigation?
Were licence plate reader returns for the campus and the surrounding streets on September 10 requested by anyone on your team, and if so, from whom?
On the police radio that afternoon, an officer asked for the plate on a Toyota 4Runner parked next to a federal vehicle. Was that plate ever run?
A plate run that day came back with no return and no history. Did anyone follow that up to a registered owner?
Was any vehicle in the courtyard area or the adjacent lots photographed, plated and eliminated, or was elimination done by description alone?
Who decided which vehicles were collected and which were released — you, your agency, or a federal partner?

Addressed to a rental records custodian, on foundation and on the retention answer:

Please describe your company's retention schedule for the rental agreement, for the driver's licence image, and for the telematics track — each separately, in days.
On the date this subpoena was served, which of those items still existed for the agreements in the window?
For an item that no longer exists, what deleted it — a scheduled purge, a system migration, or a manual action — and is there a log of that deletion?
Is this location corporate-operated or franchise-operated, and does the franchise hold records the corporate system does not?
Can you produce, from the same window, a comparison agreement unrelated to this matter, so the Court can see what a complete record from your system looks like?
Does your system record who else asked you for these same agreements, and when?
If this vehicle carried a factory connected-car service as well as your own fleet unit, is the manufacturer a separate custodian the Court would need to reach independently?

Question 12 is the control test, and it is the most important question on this page. A custodian who cannot produce a comparison record from the same window has told the Court that the system, not the case, is the reason the file is empty. A custodian who can produce one has told the Court something quite different, and has done it without accusing anybody of anything.

Two of these questions are the ones this exercise most wants answered and cannot ask any further. Question 4 and question 5 come from the police radio traffic, not from a court record — a plate requested and never read back, and a plate run that returned no history at all, both recorded on the dispatch and radio scanner timeline. Neither has a public follow-up. A subpoena to a rental company is one of the few routes that could resolve either one without naming a single person.

Why A Defense Attorney Would Want This

The State's case is a single-actor case built around a single vehicle. Every other vehicle discussed on September 10 — on the radio, in the lots, on the campus feeds — is unresolved on the public record. A defense does not need to prove that any of those vehicles matters. It needs the jury to understand that the investigation did not find out, and a rental agreement is the cheapest document in the world that can show it.

The control discipline applies here, and it is not optional. This site imported it from the flight data recovery work, where a scripted request returning HTTP 403 looked exactly like suppression and turned out to be an ordinary archive boundary — a control aircraft failed identically, and a published finding had to be retracted. The same rule governs a rental return. A record that cannot be produced is evidence of nothing until an unrelated comparison record from the same window has been produced from the same system. Retention schedules expire. Franchise locations keep books the corporate system never sees. System migrations lose years. All three destroy records for reasons that have nothing to do with this case, and all three look identical from the outside. Ask for the comparison record in the same rider, read the two returns together, and never publish an absence as a removal.

The telematics clock is the strongest day-one argument on this page. Rental fleets are now largely telematics-equipped, and the position track is by far the shortest-lived record in the file. Agreements are kept for years because tax and accounting require it. Licence images and payment records outlive the rental by a long way. But a GPS track is high-volume operational data, and the retention windows are measured in months, sometimes in weeks. A subpoena served in September or October 2025 lands inside every common telematics window and returns an actual track — where a car went, when it stopped, how long it idled. The same subpoena served today, 356 days after September 10, 2025, returns a polite letter explaining that the data has aged out. That is the cost, stated plainly: not a document redacted, not a document withheld, a document that no longer exists and that no court order can now recreate.

Set the rider against the clock item by item, and the shape of the loss is obvious. The middle column is the ordinary commercial retention behaviour for that class of record, not a representation about any particular company — every one of them is a question this rider asks the custodian to answer under paragraph 16.

Item in the rider	Typical retention behaviour	Served 19 Sept 2025	Served today
Rental agreement, agreement number, dates	Years — tax and accounting drive it	Complete	Very likely complete
Renter identity, address, account	Years, on the customer profile	Complete	Very likely complete
Driver's licence image	Often purged well before the agreement	Complete	Uncertain
Payment record	Years in settlement; card data truncated	Complete	Largely complete
VIN, plate, make, model, colour	Life of the unit and beyond	Complete	Complete
Odometer and fuel out and in	Years, on the closed contract	Complete	Complete
GPS or telematics track	Months, sometimes weeks	Complete	Almost certainly gone
Toll and violation transactions	Months to a few years, via the toll partner	Complete	Partial at best
Check-in and check-out photograph sets	Months to a couple of years	Complete	Uncertain
Counter agent identity	Years, on the transaction record	Complete	Likely complete
Agency contact or request record	Varies; often retained indefinitely	Complete	Likely complete

The rest of the rider survives the delay, which is why it is still worth serving. Names, licences, cards, VINs, plates, odometers and tolls are all long-retention records. Odometer out and odometer in is the quiet one. It is a two-number answer that bounds the total distance a vehicle travelled, it cannot be argued with, and it is retained for accounting reasons long after the track is gone.

One more reason this instrument belongs early: it is the only one in this cluster whose failure is informative on its own. An intelligence subpoena that is refused tells a jury nothing it can weigh, because refusal is what everyone expects. A rental company that answers in full and shows no relevant rental has genuinely closed a question, and a defense that closes its own weak questions early is a defense the jury trusts on the strong ones.

Day-one date: preservation letters to every rental company within twenty-five miles of Provo Municipal Airport and to the Salt Lake City International concessionaires on 12 September 2025, and the subpoena duces tecum itself on 19 September 2025, three days after the information was filed. At that date every item in the rider still existed — including the telematics tracks, the check-in photograph sets and the toll transactions, all of which sit inside the shortest retention windows in the file. The vehicles themselves were also still in fleet and still identifiable by VIN, which meant a unit could have been located and examined rather than reconstructed from paperwork. That window is closed.

The Honest Counterargument

The strongest answer is the simplest one: there may be no rentals to find. The claim that cars were issued to passengers off the Egyptian aircraft comes from flight-tracking threads, and this site's own research records that the facility named in those threads does not offer car rental. A subpoena that comes back empty from six companies has cost the defense two months and produced a fact that helps the State — the alternative-vehicle theory has no documentary support. Counsel who has already run that search privately would have every reason never to mention it again.

Second, a records subpoena is visible. Under Rule 45(b)(3), the prosecution is served with the notice and the subpoena before it issues. It tells the State exactly what the defense is chasing, and in a case where the defense's public theory is a straightforward reasonable-doubt theory built on the inconclusive comparison and the DNA mixture, announcing an interest in foreign aircraft passengers hands the prosecution a caricature to argue against. Some capital lawyers deliberately keep an unripe theory out of the noticed record until they are ready to defend it.

Third, the out-of-state problem is real. National rental companies keep their records at out-of-state headquarters, and reaching a Missouri or Florida custodian from a Utah criminal case means the certificate procedure under Utah Code 77-21-3. The State moved to quash the one such application this defense has publicly made. A team that has litigated that fight once knows what it costs.

Fourth, breadth invites a motion to quash. A rider that asks six companies for every agreement across two multi-day windows at every branch within twenty-five miles is a large ask, and a recipient who does not want the work will say so. The answer is to serve it narrow and widen on a showing — agreements and vehicle assignment records first, telematics and photograph sets on a second round once a specific unit is identified. That is slower. In September 2025 it would still have been fast enough. In 2026 the two-round approach is what loses the track, which is an argument for having served it in 2025 rather than an argument against serving it at all.

Fifth, and most uncomfortable: the record this instrument is most likely to produce is a negative one. Ninety-nine rental agreements in a September window at an airport near a university will be families, contractors and business travellers. Publishing a list of ordinary people who rented cars in Utah County would be indefensible, and no version of this exercise contemplates it. The rider is drafted to a court and to a records custodian under a protective order, and the only output that ever belongs in public is the answer to a narrow question: whether a vehicle discussed on the radio that day was ever identified.

None of that makes the instrument wrong. It makes it a decision with a real downside, taken by people who can see discovery we cannot.

Sources On This Site

:::danger Theoretical Exercise Only This page is a theoretical exercise. It is a written simulation of how an idealised defense attorney might approach this case. We make no claim that there is any problem with the current defense attorney, with any member of the defense team, or with any decision they have made.

Real capital defense is conducted under a gag order, with sealed filings, and on the basis of full discovery that the public has never seen. Counsel of record know facts we do not. A step described here as "not on the public record" may already have been taken privately, may have been considered and rejected for good reason, or may not yet be due at this stage of the case. Silence in the public record is not evidence of a failure.

Nothing here is legal advice, a criticism of any licensed attorney, or an allegation of professional misconduct. :::

This website's author is @HolonCitizen on X and YouTube/@HolonCitizen. Follow me there.

The One Thing We Would Do Differently​

The rider​

The gateway, and the crucial distinction​

What The Defense Team Did Instead​

Where This Belongs In The Case​

Witness Or Discovery Target​

The Questions That Were Not Asked​

Why A Defense Attorney Would Want This​

The Honest Counterargument​

Sources On This Site​