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that the mere filing of a complaint does not start a Sixth Amendment
document IMAGES-002-HOUSE_OVERSIGHT_014069.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

90 CASSELL ET AL. [Vol. 104 that the mere filing of a complaint does not start a Sixth Amendment prosecution also make clear that a later court hearing would start such a prosecution. For instance, in the Fourth Circuit case cited by OLC, United States v. Alvarado, the court rea...