In general, the principles discussed in this Manual at 239 et seq. with respect to lineup identifications are fully applicable to photographic identifications. See Simmons v. United States, 390 U.S. 384 (1968). The major exception to this principle is that no right to counsel attaches at photographic identifications, whether before or after indictment. United States v. Ash, 413 U.S. 300 (1972).
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