No Miranda violation occurred where the defendant invoked his right to counsel but then made incriminating statements to an undercover officer posing as a fellow inmate. Unlike in People v. Zapata (2026) 118 Cal.App.5th 529, here known law enforcement officers did nothing to “stimulate” the Perkins operation after the defendant invoked. [Editor’s Note: The admissibility of post-invocation statements to an undercover officer during a Perkins operation is currently under review in People v. Allen (July 22, 2024, B328333) [nonpub. opn.], review granted Nov. 20, 2024, S286520.]