Thus, in Levy, 256 N.Y.S.2d 793, 204 N.E.2d at 843-45, the New York Court of Appeals held that an abduction of the victims from in front of their home and driving them a distance of twenty-seven blocks to rob them of their money and jewelry did not give rise to kidnapping. Similarly, in People v. Lombardi 20 N.Y.2d 266, 282 N.Y.S.2d 519, 229 N.E.2d 206, 207-08 (1967), the New York Court of Appeals reversed kidnapping convictions in which the defendant drugged women, drove them from Manhattan to a motel in Queens, and held them there for a number of hours as part of attempted sexual assaults. The court held that the confinements involved were incidental to the attempted rapes. Id., 282 N.Y.S.2d 519, 229 N.E.2d at 209; see also Daniels, 80 Cal. Rptr. 897, 459 P.2d at 226-28, 238 (<HOLDING>). The “facilitate is incidental” approach
holding that the victims statement was inadmissible when made two to three hours after victim was allegedly raped because the victims testimony supported the conclusion that her statement was made with conscious reflection holding that the applicant was entitled to asylum based on her fear that her daughter will be forced to undergo female genital mutilation because her fear of  being forced to witness the pain and suffering of her daughter is wellfounded holding that a victims statement to her sister that she had been raped was an excited utterance when between the time of the assault and her making the statement the victim dressed herself and walked down the stairs holding that evidence was sufficient to support convictions for two counts of armed robbery when money was taken from one victims immediate presence at gunpoint and given to second victim and second victim was then forced to surrender the money to defendant at gunpoint holding evidence insufficient to support kidnapping in four rapes in which 1 attacker held knife to victim and forced her into car where he raped her 2 assailants forced their way into victims home walked victim through dining room into kitchen put dish towel over her face and raped her 3 attackers forced way into victims apartment one pulled out gun took victim to couch for oral sex then took her into adjoining bathroom raped her and threatened to rip out phone and 4 assailants forced their way into victims apartment at gunpoint put hand over victims mouth walked her toward kitchen and then to bedroom checking first to see if anyone was present and then raped her