Is Section 654 of the Criminal Code applicable in determining whether multiple felonies arise from the same set of operative facts?

People v. McKee (1995) 36 Cal.App.4th 540, 42 Cal.Rptr.2d 707, held the "traditional section 654 analysis is apposite in deciding whether multiple new felonies arise from the same set of 'operative facts' within the meaning of the 'three strikes' law. [Citation.]" (Id. at p. 546, 42 Cal.Rptr.2d 707.)

Likewise, People v. Martin, supra, 32 Cal.App.4th 656, 38 Cal.Rptr.2d 776, held subdivision (c)(6) invoked the principles of section 654.

"The 'same set of operative facts' provision in subdivision [sic ] section 667, subdivision (c)(6) serves an important function,

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