California, United States of America
The following excerpt is from People v. Galvez, B286807 (Cal. App. 2019):
3. A defendant's presence need not be concealed from his victim while watching and waiting. (See People v. Morales (1989) 48 Cal.3d 527, 555, disapproved on another ground in People v. Williams (2010) 49 Cal.4th 405, 459 ["[T]he evidence was sufficient to support a finding of lying-in-wait murder, based on defendant's watchful waiting, from a position of advantage in the backseat, while the car was driven to a more isolated area, and his sudden surprise attack, from behind and without warning, on [the] victim"].)
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