California, United States of America
The following excerpt is from People v. McKnight, A143997 (Cal. App. 2016):
21. "Lying-in-wait murder consists of three elements: ' " '(1) a concealment of purpose, (2) a substantial period of watching and waiting for an opportune time to act, and (3) immediately thereafter, a surprise attack on an unsuspecting victim from a position of advantage.' " ' " (People v. Russell (2010) 50 Cal.4th 1228, 1244, fn. omitted.)
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