P. v. Guinea
Nothing in section 186.22, subdivision (b), requires that the so-called “predicate†offenses actually predate the charged offense. Subdivision (e) defines a “‘pattern of criminal street gang activity’†as “the commission of . . . two or more of the following offenses, provided at least one of these offenses occurred after the effective date of this chapter and the last of those offenses occurred within three years after a prior offense; and the offenses were committed on separate occasions, or by two or more persons.†The only temporal requirement is that the first and last of these offenses have been committed no more than three years apart.
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