In People v. Bergschneider (1989) 211 Cal. App. 3d 144, the 14-year-old, slightly retarded, victim put her hands in front of her vagina to resist his act of intercourse but the defendant pushed her hands away. In another incident the victim unsuccessfully tried to push the defendant's head away while he was orally copulating her. The court found the gestures used by the defendant to overcome the victim's resistance was "force" greater than and different from that necessary to accomplish the lewd acts. (People v. Bergschneider, supra, 211 Cal. App. 3d 144, 153.)