California, United States of America
The following excerpt is from People v. Garcia, H040067 (Cal. App. 2015):
predicate offense, because the combined activity of a defendant and an aider and abettor to the crime results in only a single predicate offense for purposes of section 186.22. (People v. Zermeno (1999) 21 Cal.4th 927, 928-929, 931.)
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