In People v. Fonseca (1995) 36 Cal.App.4th 631, a codefendant pleaded guilty and then refused to testify. After an exhaustive review of both state and federal cases ( id. at pp. 633-637) the court concluded "that a convicted defendant retains his Fifth Amendment privilege as to subsequent proceedings against other defendants at least until the time he no longer retains the right to file a timely notice of appeal." ( Id. at p. 633; see also People v. Lopez (1999) 71 Cal.App.4th 1550, 1554; In re Robert E. (2000) 77 Cal.App.4th 557, 560.) Butler asks us to reject this bright-line rule in favor of "a particularized inquiry" ( People v. Lucas (1995) 12 Cal.4th 415, 454, 907 P.2d 373) into "the substantiality of the risks of incrimination" ( Marchetti v. United States (1968) 390 U.S. 39, 54, 19 L. Ed. 2d 889, 88 S. Ct. 697; see also Zicarelli v. New Jersey Investigation Comm'n (1972) 406 U.S. 472, 478, 32 L. Ed. 2d 234, 92 S. Ct. 1670 privilege protects against real dangers, not remote and speculative possibilities).