How has the continuous course of conduct exception been interpreted in the context of sexual abuse cases?

^5. The court's comments referred to the well-settled principle that the continuous course of conduct exception " 'arises in two contexts. The first is when the acts are so closely connected that they form part of one and the same transaction, and thus one offense. [Citation.] The second is when... the statute contemplates a continuous course of conduct of a series of acts over a period of time. [Citation.] [] 'This second category of the continuous course of conduct exception has been applied to a limited number of varying crimes, '" including specific sexual abuse offenses. (People v. Avina (1993) 14 Cal.App.4th 1303, 1309; People v. Culuko (2000) 78 Cal.App.4th 307, 325.) As we will explain, post, the court correctly relied on the first aspect of the continuous course of conduct exception to deny the unanimity instruction in this case.

^6. While the statutory definition of the offense of committing a criminal threat does not fall within the statutory aspect of the continuous course of conduct exception (People v. Salvato (1991) 234 Cal.App.3d 872, 882-883), that does not preclude a finding that acts constituting the crime were so closely connected that they formed part of one and the same transaction. (People v. Avina, supra, 14 Cal.App.4th at p. 1309.)