[37] Planning is to be given its traditional meaning: “…that does not mean, of course, to say, that the plan need be a complicated one. It may be a very simple one, and the simpler it is perhaps the easier it is to formulate. The important aspect is the time it takes to prepare a plan and not the time between developing the plan and doing the act.” R v. Ali [2016] O.J. No. 1635
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