What factors must be considered in determining whether a charge of sexual assault against a minor is inextricably intertwined or closely related?

Covarrubias also observed United States v. Hines, supra, 963 F.2d 255, "failed to identify the specific factors that we are to consider in determining whether the two offenses are inextricably intertwined or closely related." (United States v. Covarrubias, supra, 179 F.3d at pp. 1224-1225.)

Covarrubias undertook to do so (not too successfully, as will appear) after first summarizing the tests applied by some other federal appellate courts, i.e., "whether charges 'arise from the same incident'"; whether they are "'extremely closely related'"; and whether the uncharged offenses are "'very closely related crimes which arise out of the same course of conduct as the charged offenses.'" (United States v. Covarrubias, supra, 179 F.3d at p. 1224, fn. 7.)