P. v. Martinez CA4/3
” The test is whether the physical force used was “‘substantially different from or substantially in excess of that required for the lewd act.’” (People v. Babcock (1993) 14 Cal.App.4th 383, 385 (Babcock).) “‘[A]n act is forcible if force facilitated the act rather than being merely incidental to the act.’ [Citation.] ‘[A]cts of grabbing, holding and restraining that occur in conjunction with the lewd acts themselves’ are sufficient to



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