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Since the early 90's it has been possible to hack the BIOS on a phone and track other phones as they move in and out of cells. With a hacked phone and a frequency counter, you could triangulate the position of the phone being tracked. I don't know if this can still be done, but the phone companies can triangulate the position based on signal strength and TTR from each tower. As long as the phone is powered on, it can be done.
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