This one is really easy to get in the racer tutorial.
To finish the tutorial you have to drive back to your hideout...dont do this.
Instead continue to drive head-to-head races. There wont be any police, but your heat-level and multiplicator will still raise.
After 10-12 races you should get this one along with "Multiplier"
Credit for figuring this out goes to 360a.org user IRELAND NO 1. I just tested this method and thought it would be helpful if everyone could also read it here before they are going to finish the tutorial