In People v. Rodriguez (1986) 42 Cal.3d 730, the California Supreme Court held that the trial court did not err in admitting evidence of defendant's prior criminal conduct to prove the elements of premeditation, willfulness, and malice aforethought in the prosecution's case-in-chief. ( Id. at pp. 757-758.) The defendant contended that those elements were not in issue because his defense at trial was regarding the issue of identity. (Ibid.) However, the court found that the defendant's defense was not revealed until the prosecution rested and noted that the prosecution was required to establish every element of the crime prior to the close of its case-in-chief. ( Id. at p. 758.)