Is there insufficient evidence to prove that a defendant was armed with a firearm when he committed his crimes?

Hearn suggests the evidence is insufficient to show he was armed with a firearm when he committed his offenses because the firearm in question could have been stored in the trunk of the vehicle he was driving so that he had no ready access to it. Specifically, citing People v. Jones (1977) 72 Cal.App.3d 624 (Jones), he asserts that "[a] defendant may carry a concealed firearm in a vehicle . . . and not be armed with that firearm. He may, for example, have placed the firearm in the trunk of his car."