California, United States of America
The following excerpt is from People v. Sankikian, B282229 (Cal. App. 2019):
or by two or more persons." (Italics added.) What the italicized language means is that the last of the predicate offenses must have occurred within three years after a prior offense. (People v. Fiu (2008) 165 Cal.App.4th 360, 388.)
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