The information was disclosed during a pretrial hearing in US District Court as lawyers for three of Tsarnaev's friends asked a judge to order prosecutors to turn over a variety of records and documents to the defence.
The defence requested all communications between Tsarnaev and the three men, as well as all communications between Tsarnaev and other people.
Authorities allege that the friends went to Tsarnaev's dorm room at the University of Massachusetts-Dartmouth several days after the bombings, soon after the FBI posted photographs of the two bombing suspects, Tsarnaev and his older brother.
Another friend, Robel Phillipos, is charged with lying to authorities while he was being questioned.
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All three men have pleaded not guilty and their lawyers have said they had no prior knowledge of Tsarnaev's alleged involvement in the marathon bombing.
Robert Stahl, Kadyrbayev's lawyer, said prosecutors told defense attorneys that Tsarnaev destroyed his cellphone before his arrest. Stahl said that in other cases he's had, some text messages have been retrieved from cellphones through a service provider.