Midrash for Chullin 278:24
מכי יקרא נפקא כי יקרא פרט למזומן
For Rab Judah said in the name of Rab: If a man found a nest in the sea<span class="x" onmousemove="('comment',' A tree was washed away into the sea and upon it was a bird's nest.');"><sup>10</sup></span>
Sifrei Devarim
(Devarim 22:6) "If there chance before you a bird's nest": to exclude what is normally found there.
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