TO SUSTAIN EXCLUSION OF IDENTIFICATION TESTIMONY BASED ON PHOTOGRAPHIC EVIDENCE, THERE MUST BE NOT ONLY A SHOWING OF IMPERMISSIBLY SUGGESTIVE PROCEDURES, BUT ALSO A RESULTING SUBSTANTIAL LIKELIHOOD FOR MISIDENTIFICATION. USE OF SURVEILLANCE PHOTOGRAPHS, HOWEVER, IS NOT SUGGESTIVE SINCE IT SHOWS THE ACTUAL INDIVIDUAL IN THE COMMISSION OF THE CRIME, AND BY REFRESHING THE MEMORY OF WITNESSES, DIMINISHES THE LIKELIHOOD OF MISIDENTIFICATION. COURT RESTRICTIONS ON THE SIMULTANEOUS VIEWING OF ROBBERY SURVEILLANCE PHOTOS BY MULTIPLE WITNESSES, THE USE OF PHOTOS TO REFRESH THE MEMORY OF WITNESSES DURING THEIR TESTIMONY, AND THE IDENTIFICATION OF CRIMINALS FROM SURVEILLANCE PHOTOS OF OTHER CRIMES ARE DISCUSSED.