In People v. Burnell (2005) 132 Cal.App.4th 938, the Court held trial counsel was not ineffective for having failed to request severance/bifurcation of substantive street terrorism counts and gang enhancements because it was unlikely such a motion would have been granted. After explaining why severance of the substantive street terrorism counts was not necessary, the court observed: "If a severance of the street terrorism charge was highly unlikely, the bifurcation of the gang enhancements was even more unlikely. Virtually all f the gang evidence which would be admissible on the gang enhancements would also be admissible on the street terrorism charge. Thus, the jury would hear the evidence during trial of the substantive gang offense. Further, 'any evidence admitted solely to prove the gang enhancement was not so minimally probative on the charged offense, and so inflammatory in comparison, that it threatened to sway the jury to convict regardless of defendants' actual guilt.'" (Id. at p. 948.)