In People v. Westbrook (1996) 43 Cal.App.4th 220, the court termed the "'sham separate sovereign'" argument a "narrow exception" to the rule that prosecutions undertaken by separate sovereigns are permissible. (Westbrook, at pp. 224-225.) In that case, a prosecuting attorney averred that the prosecutions were separate, and the Court of Appeal rejected the claim they were not. (Id. at p. 225.)