In what circumstances will a defendant be able to cross-examine an out-of-court identification?

In addition to cross-examination, a further safeguard against convictions based on unreliable out-of-court identifications lies in the ability of the defendant to offer other evidence casting doubt on the identification, such as evidence that the identifying witness was not present at the scene of the crime, was not previously familiar with the defendant, or had a motive to implicate the defendant. Moreover, the defendant is free to seek appropriate instruction directing the jury's attention to the issue of identification and to the factors affecting the probative value of the out-of-court identification. (See CALJIC Nos. 2.91, 2.92; People v. Wright (1988) 45 Cal.3d 1126, 1144, 248 Cal.Rptr. 600, 755 P.2d 1049.)