What is the definition of "permanence" for a defendant to be liable under section 273.5 of the California Code of Civil Procedure for sexual assault?

definition refers only to the underlying "substantial relationship," not to the actual living arrangement.' [Citation.] Permanence does not require exclusivity in either the relationship or the living arrangement. [Citation.] '[F]or purposes of criminal liability under section 273.5, a defendant may cohabit simultaneously with two or more people at different locations, during the same time frame, if he maintains substantial ongoing relationships with each and lives with each for significant periods.' [Citation.]" (People v. Taylor (2004) 118 Cal.App.4th 11, 18-19.)

In People v. Holifield (1988) 205 Cal.App.3d 993, the appellate court held that there was sufficient evidence of cohabitation under the following circumstances: "[D]efendant lived with [the victim] at [a] hotel half or more of the three months preceding the assault and had no other regular place to stay. When there, he slept and had occasional sex with her, although he ate few meals there and often went out alone evenings after work. He brought his few belongings with him each time he returned to her. They did not share rent, a bank account or the cost of furnishings, but . . . [s]uch sharing is not essential . . . . The sex, though infrequent, and [the victim]'s romantic feelings for him, though unreturned, show an intimacy going well beyond that of ordinary roommates. Finally, the jury could reasonably have found an ongoing relationship of 'some permanency' . . . ." (Id. at p. 1002.)