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People v. Williams, 97 Cal. App. 3d 382 - Cal: Court of Appeal, 2nd Appellate Dist., 5t... - 0 views

  • hey assert that a conspiracy terminates when the primary object of the conspiracy is complete
  • . Further, as discussed immediately below, it misconstrues the notion of the "primary object" of a conspiracy.
  • (3) We agree with defendants that for purposes of the statute of limitations, a conspiracy terminates upon the completion of its primary object; acts committed subsequent to such completion cannot be deemed overt acts in the furtherance of the conspiracy. (People v. Zamora (1976) 18 Cal.3d 538, 554, fn. 12, 560 [134 Cal. Rptr. 784, 557 P.2d 75]
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  • use it erroneously equates "primary object of a conspiracy" with the subjective ultimate goals of the conspirators. On the contrary, a close reading of Zamora makes clear that the term "primary object" has a somewhat technical rather than ordinary meaning; it refers to the substantive offense which the conspirators agree to commit. (Ibid.)
  • Thus, in order to determine when the three conspiracies terminated, the court looked to the time when the substantive offense underlying each conspiracy was completed. (Id., at p. 554, fn. 12.) The court found that the central object of the conspiracy to commit grand theft was the 390*390 obtaining of insurance proceeds under false pretenses; hence, such conspiracy terminated upon the receipt of the last payment. (Id., at pp. 555, 560.)
  • In Williams v. Superior Court, supra, 81 Cal. App.3d at pages 344, 345, the companion case to the one currently before us, we held that concealment is a continuing crime if the facts demonstrate a continuing pattern of purposeful concealment.
  • are
  • A reading of People v. Gilbert (1938) 26 Cal. App.2d 1, 25-26 [78 P.2d 770], convinces us that this contention lacks merit. In that case, immunity was granted to two of the persons who had allegedly participated in three conspiracies. The remaining defendants argued that the persons granted immunity could not be counted as coconspirators for purposes of determining whether a conspiracy had been committed. (8) The
    • io_cicero
       
      Dylina 1983 STump if he is a conspriator or not does not depend on others for conspriing  a state action was involved...he participated in that actoin, and the signature of order to conceal further the conspiracy. What is the object of the conspriacy to deplete all of the money to pay in full every premium to complete the insurance contract TO COMPLETE THE INSURANCE CONTRACT PAY FOR EVERY PREMIUM until the maturity date, and now the death. that locks in the owner of the policy.
  • As in Gilbert, the grant of immunity to Ms. Hoover is not inconsistent with her culpability as a coconspirator. Her acts in furtherance of the conspiracy may therefore be considered in establishing the culpability of her fellow coconspirators. (See, also, People v. Hadden (1947) 79 Cal. App.2d 635 [180 P.2d 3
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