California, United States of America
The following excerpt is from People v. Ortega, B278160 (Cal. App. 2017):
To prove a pattern of criminal gang activity, there must be proof of two or more "predicate offenses" enumerated in section 186.22, subdivision (e), not necessarily gang related, but committed on separate occasions, the last of which occurred within three years after a prior offense. (People v. Gardeley
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