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The right to present a defense, of course, is not absolute, as defendants in criminal cases 'must comply with established rules of procedure and evidence designed to assure both fairness and reliability.' Washington, 2001 U.S. App. LEXIS 13480, at *28 (quoting Chambers, 410 U.S. at 302). On the other hand, state rules of evidence may not be 'inflexibly applied' so that they deprive a defendant of a fundamentally fair trial. See id. Indeed, the Supreme Court held in Chambers that 'where constitutional rights directly affecting the ascertainment of guilt are implicated, the hearsay rule may not be applied mechanistically to defeat ...