Is there a presumption that counsel must be present at the time of a post-police interview before a face-to-face confrontation?

1 In fact, the dictum cuts both ways. Several courts have implicitly assumed that counsel, no matter how passive his role may be, is present at some point before the face-to-face confrontation. See, e.g. United States v. Wilcox, 507 F.2d 364, 369 n. 22 (4th Cir.1974), cert. denied, 420 U.S. 979, 95 S.Ct. 1408, 43 L.Ed.2d 661 (1975) (holding no right to counsel at post lineup interviews but interpreting the critical phase requiring counsel as "the time period involved in the actual setting up and operation of the confrontation of the accused and witness.") (emphasis added).