California, United States of America
The following excerpt is from People v. Perez, B223276 (Cal. App. 2011):
Here, evidence of all three types supports a finding of premeditation and deliberation. First, there is sufficient evidence of planning activity. Appellant parked his bicycle at a nearby market rather than at the victim's apartment. (Perez, supra, 2 Cal.4th at p. 1126 [fact that defendant did not park his car in the victim's driveway was planning activity]; People v. Hillery (1965) 62 Cal.2d 692, 704 [fact that defendant parked his car a short distance from the victim's home and approached on foot was planning activity].)
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