How have courts dealt with multiple sex crimes committed in the same incident?

Where several sex offenses are committed in the same incident, it is not enough to say the defendant harbored a single objectivesexual gratification. Such an objective "is much too broad and amorphous to determine the applicability of [Penal Code] section 654." (People v. Perez (1979) 23 Cal.3d 545, 552.) In People v. Bright (1991) 227 Cal.App.3d 105, the court upheld multiple punishment of lewd acts and other sexual offenses committed during a single incident, where none of the separate acts was "necessary for or incident to" the others. (Id. at p. 110.)