In People v. Ordonez (1991) 226 Cal.App.3d 1207, the charges alleged aggravated kidnapping for ransom, extortion, or reward. Under the instruction of his employer, a defendant arrived at the victim's house with accomplices, whom he directed to put the victim in the trunk of a car. He delivered a note to the victim's wife demanding that she deliver the money to him in the family's bank accounts and deposit box. The appellate court concluded that such acts established that the defendant was a "willing and continuing participant in a crime designed to carry off and hold the victim until the property sought from him had been obtained." (Ibid.) There was no direct evidence of the agreement between the defendant and his employer, but the court cited People v. Lipinski (1976) in support of the conclusion that the defendants' conduct in carrying out the conspiratorial purpose supported the inference of a conspiratorial agreement.