The following excerpt is from Anderson v. United States, 406 F.2d 770 (9th Cir. 1969):
The appellant's argument in our court is that we should extend the doctrine of United States v. Wade, 388 U.S. 218, 87 S.Ct. 1926, 18 L.Ed.2d 1149 (1967), and hold that the pretrial exhibition of the photographs to the prospective witnesses was impermissible without the presence, during the exhibitions, of an attorney representing the accused. In the circumstances of this case, it is unnecessary for us to consider that contention.
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