What is the legal test for a "lying in wait" murder?

"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.) "The required concealment need not be physical. It suffices if the defendant's purpose and intent are concealed by his actions or conduct, and the concealment of purpose puts the defendant in a position of advantage, from which the fact finder may infer that lying in wait was part of the defendant's plan to take the victim by surprise." (People v. Ceja (1993) 4 Cal.4th 1134, 1140.) "Although we have held the period of watchful waiting must be 'substantial' [citation], we have never placed a fixed time limit on this requirement. Indeed, the opposite is true, for we have previously explained that

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