identification are suggestive, reliability is the linchpin for determining admissibility.” United States v. Matthews, 20 F.3d 538, 547 (2d Cir.1994). Castillo’s trial counsel raised the issue of a curative or adverse inference charge or independent source hearing with respect to not receiving notice that the witnesses would be making in-court identifications, rather than directly challenging the reliability of the identifications. (See Tr., Yol. 2, at 245-46, 304-07.) In rejecting these requests, the trial court correctly noted that the purpose of giving notice of in-court identifications is to provide the defendant adequate opportunity to test the suggestiveness of police identification procedures, pursuant to United States v. Wade, 388 U.S. 218, 87 S.Ct. 1926, 18 L.Ed.2d 1149 (1967) (<HOLDING>). The trial court rightly stated, however, that
holding that a showup identification was not impermissibly suggestive where it took place immediately after the unlawful conduct and was necessary to avoid arresting the wrong person holding due process requires suppression of testimony regarding pretrial identification when procedure employed is impermissibly suggestive holding that a spontaneous accidental identification by two law enforcement officials of a suspect in handcuffs upon their return to the police station was not impermissibly suggestive recognizing due process violation when suggestive identification procedures create a very substantial likelihood of irreparable misidentification holding that to protect defendants sixth amendment rights a court must determine whether witness identification testimony was tainted by impermissibly suggestive procedures