Does a suspect need the assistance of counsel to insure fairness of any in person pretrial identification arranged by the police?

A suspect needs the assistance of counsel to insure the fairness of any in person pretrial identification arranged by the police and to prepare his counsel for effective cross-examination at the trial of the People's witnesses participating in the identification regardless of when the identification occurs or its exact nature, subject to two exceptions. These are: (1) an immediate identification under exigent circumstances such as existed in Stovall, supra, 388 U.S. 293, 302, 87 S.Ct. 1967, 18 L.Ed.2d 1199, 1206; and (2) a field identification occurring so immediately after the crime that the participating victim's or eyewitness' identification is without question based entirely on his recollection of the suspect at the time of the crime. This latter form of pretrial in person identification is trustworthy, reliable, and ordinarily immune to any suggestion by the police. Furthermore, the making of such an identification may be as advantageous to the suspect as it is to the police. (See People v. Irvin, 264 Cal.App.2d 747, 759--760, 70 Cal.Rptr. 892; People v. Colgain, 276 A.C.A. 147, 154--156, 80 Cal.Rptr. 659; People v. Levine, 276 A.C.A. 251, 253, 80 Cal.Rptr. 731.)