In a matter involving allegations of bribing members of a board of supervisors to obtain their approval of a litigation settlement, the California Supreme Court held: “Whether the offeror is guilty of aiding and abetting the receipt of the bribe depends on whether there is evidence that, in addition to the offer or payment of the bribe, the offeror ‘with (1) knowledge of the unlawful purpose of the perpetrator; and (2) the intent or purpose of committing, encouraging, or facilitating the commission of the offense, (3) by act or advice aids, promotes, encourages or instigates, the commission of the crime.’” (People v. Biane (Cal. Sup. Ct.; December 23, 2013) 58 Cal.4th 381, [315 P.3d 106].)
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