Can a jury infer that defendant devised a plan to kill the victim to avoid detection for sexual assault during or after the sexual assault?

As to planning, courts have found that planning activity can happen during an altercation itself and "over a short period of time . . . ." (See, e.g., People v. Sanchez, supra, 12 Cal.4th at p. 34, italics added [planning activity occurred during the altercation, in the moments that the son sought out and obtained a kitchen knife to kill his father].) Here, the jury could reasonably infer that defendant devised the plan to kill the victim to avoid detection for the sexual assault during or after the sexual assault, and that he applied pressure to her neck for up to five minutes to carry out that plan.